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-09662

Type - Initial Exploration Plan

Lease(s) - OCS-G32678 Block - 416 Walker Ridge Area OCS-G32688 Block - 460 Walker Ridge Area

Operator - ConocoPhillips Company

Wells A, B and D

DRILLSHIP

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

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

Chiquita Hill Plan Coordinator Description -

Rig Type - Subject: From: October 25, 2012

## PUBLIC INFORMATION August, 2012



## INITIAL EXPLORATION PLAN

Lease Number(s): OCS-G 32678/32688

Area/Block: Walker Ridge Blocks 416 and 460
Prospect Name: Thorn

Offshore: Louisiana

Submitted by: Conoc oPhillips Company 600 North Dairy Ashford Road Houston, Texas 77079-1175

Bruce R. Wilcoxon (281) 293-5337 Bruce.R.Wilcoxon@ConocoPhillips.com



## Estimated startup date: January, 2013

Authorized Representative: No. of Copies Being Submitted: Jodie Connor or Judy Davids on Proprietary: 1 & CD J. Connor Consulting, Inc. Public Info: 1 & CD 16225 Park Ten Place, Suite 700 Houston, Texas 77084 For BOEM: (281) 578-3388 Plan No. jodie.connor@jccteam.com or judy.davidson@jccteam.com Assigned to:

### RECORD OF CHANGES

Date Section Page Remarks

08/21/12 All All Submittal of Initial EP 09/12/12 F Attachment F-1 Waste Discharge Table was amended to include completion fluids. L Attachment L-1 Onshore Waste Disposal Tabl e was amended to revise the disposal method for recycl able trash and debris to recycle. 09/20/12 L Attachment L-1 Onshore Waste Disposal Ta ble was revised to amend Trash and Debris (non-recy clable) to a total of 120,000 bbls per well, and Trash and Debris (non-recyclable) to burial.

### CONOCOPHILLIPS COMPANY

INITIAL EXPLORATION PLAN

LEASES OCS-G32678 AND 32688

WALKER RIDGE BLOCKS 416 AND 460

SECTION A Plan Contents

SECTION B General Information

SECTION C Geological, Geophysical Information

SECTION D H2S Information

SECTION E Biological, Physical and Socioeconomic Information

SECTION F Wastes and Discharge Information

SECTION G Air Emissions Information

SECTION H Oil Spills Information

SECTION I Environmental Monitoring Information

SECTION J Lease Stipulations Information

SECTION K Environmental Mitigation Measures Information

SECTION L Support Vessels and Aircraft Information

SECTION M Onshore Support Facilities Information

SECTION N Coastal Zone Management Act (CZMA) Information

SECTION O Environmental Impact Analysis

SECTION P Administrative Information

## List of Attachments

Attachment A-1 OCS Plan Information Form Attachment A-2 Well Location Plat Attachment A-3 Bathymetry Map Attachment A-4 Pay.Gov Receipt Attachment B-1 Blowout Scenario Attachment C-1 Structure Map Attachment C-2 Seismic Lines Attachment C-3 Cross Sections Attachment C-4 Shallow Hazards Assessment Attachment C-5 Stratigraphic Column Attachment C-6 Isopach Map Attachment E-1 Biological Map Attachment F-1 Generated Wastes Table Attachment H-1 Spill Response Discussion Attachment L-1 Wastes Transported To Shore Table Attachment L-2 Vicinity Map Attachment N-1 Louisiana Coastal Zone Management Certification

## SECTION A PLAN CONTENTS

(A) PLAN INFORMATION FORM ConocoPhillips Company (ConocoPhillips) was awarded Walker Ridge Blocks 416 and 460 at Central Gulf of Mexico Sale Nu mber 206. The lease expiration date for both leases is July 31, 2018. To date, no operations have be en conducted on these two blocks.

Under this initial EP, ConocoPhillips proposes to drill, test and complete three wells. Additional operations which will be covered under this Initi al EP include the settin g of a subsea wellhead over the proposed well locations.

These wells will be drilled with a Dynamically Positioned Drillship and will involve a subsea BOP stack. Subsea wellheads will be installed with the drilling unit on location. See attached OCS Plan Information Form included as Attachment A-1

.
(B) LOCATION Included as Attachment A-2 is a Well Location Map depicti ng the proposed surface and bottomhole locations of the proposed wells. Also included as Attachment A-3 is a Bathymetry Map showing the water depths across the lease blocks and the locations of the proposed wells.

(C) SAFETY AND POLLUTION PREVENTION FEATURES Safety features on the drilling unit will includ e well control, pollution prevention, and blowout prevention equipment as described in 30 CFR Part 250, Subparts C, D, E, and O; and as further clarified by BSEE Notices to Lessees, and cu rrent policy making invoked by the BOEM, BSEE, Environmental Protection Agency and the U.S. Coast Guard. Schematics of the BOP and control system will be provided with the Applications for Permit to Drill as required by NTL No. 2010- N10. An approved welding procedure and schema tic of the location of the designated safe welding areas will also be available on the rig.

The rig will be equipped with sa fety and fire-fighting equipment required to comply with USCG and ABS requirements. Appropriate life saving equipment such as life rafts, life jackets, ring buoys, etc., as prescribed by the U.S. Coast Guard, will be maintained on the rig at all times.

Pollution prevention measures include installation of curbs, gutters, drip pans, and drains on drilling deck areas to collect all contaminants and debris. Compliance will be maintained with the EPA NPDES Permit which covers the leases. The rig will be monitored daily and any waste or fuel resulting in pollution of the Gulf waters will be reported to the representative in charge for immediate isolation and correction of the problem. Any spill will be reported to the appropriate governmental agencies.

ConocoPhillips Company August, 2012 Initial Exploration Plan Page A-1 Walker Ridge Blocks 416 and 460 (OCS-G 32678 and OCS-G 32688)ConocoPhillips Company August, 2012 Initial Exploration Plan Page A-2 Walker Ridge Blocks 416 and 460 (OCS-G 32678 and OCS-G 32688) 

### (D) STORAGE TANKS AND/OR PRODUCTION VESSELS All facility tanks of 25 barrels or more:

Type of Storage Tank Type of Facility Tank Capacity (bbls) Number of Tanks Total Capacity

(bbls) Fluid Gravity (API)

Fuel oil (Marine Diesel) Drillship 32,000 3 96,000 32.4°



### (F) ADDITIONAL MEASURES ConocoPhillips does not propose additional safety, pollution prevention, or early spill detection measures beyond those required by 30 CFR 250.

(G) COST RECOVERY FEE Included as Attachment A-4 is a Pay.Gov receipt in the amount of $10,326.00 (Agency Tracking Number 74335790394).U.S. Department of the Interior OMB Control Number: 1010-0151 Minerals Management Service OMB Approval Expires: July 31, 2008 

## OCS PLAN INFO RMATION FORM
GENERAL INFORMATION
Type of OCS Plan: X Exploration Plan (EP) Deve lopment Operations Coordination Document (DOCD) Company Name: ConocoPhillips Company BOEM Operator Number: 00056

Address:

600 North Dairy Ashford Road Contact Person: Jodie Connor or Judy Davidson

Houston, Texas 77079 Phone Number: (281) 578-3388

Email Address: Jodie.Connor@jccteam.com or Judy.Davidson@jccteam.com Lease(s):32678/32688 Area: WR Block(s): 416/ 460 Project Name (If Applicable): Thorn

Objective(s): Oil Gas Sulphur Salt Onshore Base: Fourchon, LA Distance to Closest Land (Miles): 171
Description of Proposed Activities (Mark all that apply)
Exploration drilling Development drilling Well completion Installation of production platform Well test flaring (for more than 48 hours) Installation of production facilities Installation of caisson or platform as well protection structure Installation of satellite structure
Installation of subsea wellheads and/or manifolds Commence production Installation of lease term pipelines Other (Specify and describe) Have you submitted or do you plan to submit a Conservation Information Document to accompany this plan? Yes X No Do you propose to use new or unusual technology to conduct your activities? Yes X No Do you propose any facility that will serve as a host facility for deepwater subsea development? Yes X No Do you propose any activities that may disturb a BOEM-designated high-probability archaeological area? Yes X No Have all of the surface locations of your proposed activities been previously reviewed and approved by BOEM? Yes X No Tentative Schedule of Proposed Activities
Proposed Activity Start Date End Date No. of Days Drill, complete and install subsea wellhead and TA Well Location A 01-01-13 04- 27-13 116 Drill, complete and install subsea wellhea d and TA Well Locati on B 01-01-14 04-27-14 

### 116 Drill, complete and install subsea wellhea d and TA Well Locati on D 01-01-15 04-27-15 

### 116

Description of Drilling Rig Description of Production Platform
Jackup Drillship Caisson Tension leg platform Gorilla Jackup Platform rig Well protector Compliant tower
Semisubmersible Submersible Fixed platform Guyed tower
DP Semisubmersible Other (Attach Description) Subsea manifold Floating production system Drilling Rig Name (If Known): Spar Other (Attach description) Description of Lease Term Pipelines
From (Facility/Area/Block) To (Facility/Area /Block) Diameter (inches) Length (Feet)



### BOEM Form BOEM-137 (October 2011 - Supersedes all previous editions of form BOEM-0137 which may not be used. *Collection has been submitted to OMB and is automatically renewed each month until approval.) 

### ATTACHMENT A-1

### OCS PLAN INFORMATION FORM (CONTINUED) 

### Include one ConocoPhillips of this pa ge for each proposed well/structure

BOEM Form BOEM-137 (October 2011 - Supersedes all previous editions of form BOEM-0137 which may not be used. Proposed Well/Structure Location

Well or Structure Name/Number (If renaming well or structure, reference previous name): A Subsea Completion

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

Surface Location Bottom-Hole Location (For Wells)

Lease No. OCS-G 32688

Area Name WR

Block No. 460

Blockline Departures (in feet) N/S Departure: 2,622’ FNL

E/W Departure: 2,457’ FEL

Lambert X-Y coordinates X: 2,310.183’

Y: 9,628.098’

Latitude/ Longitude 26 o 31’ 09.16”

90 o 57’ 04.84”

TVD (Feet): MD (Feet Water Depth (Feet):-6,915
Anchor Locations for Drilling Rig or Construction Barg e (If anchor radius supp lied above, not necessary) Anchor Name or No. Area Block X Coordinate Y Coordinate Length of Anchor Chain on Seafloor

X = Y =

X = Y =

X = Y =

X = Y =

X = Y =

X = Y =

X = Y =
Paperwork Reduction Ac t of 1995 Statement: The Paperwork Reduction Act of 1995 (44 U.S.C. Chapter 35) requires us to inform you that BOEM collects this information as part of an applicant’s Exploration Plan or Development Operations Coordination Document submitted for BOEM approval. We use the information to facilitate our review and data entry for OCS plans. We will protect proprietary data according to the Freedom of Information Act and 30 CFR 550.197. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently vali d Office of Management and Budget Control Number. The use of th is form is voluntary. The public reporting burden for this form is included in the burden for preparing Exploration Plans a nd Development Operations Coordination Documents. We estimate that burden to average 600 hours per response, or 640 with an accompanying EP (1,000 hours in AKOCSR), or 690 (1,700 in AKOCSR) with an accompanying DPP or DOCD including the time for reviewing instructions, ga thering and maintaining data, and completing and reviewing the forms associated with subpart B. Direct comments regarding the burden estimate or any other aspect of this form to the Information Collection Clearance O fficer, Bureau of Ocean Energy Management, 381 Elden Street, Herndon, VA 20170.

### OCS PLAN INFORMATION FORM (CONTINUED) 

### Include one ConocoPhillips of this pa ge for each proposed well/structure

BOEM Form BOEM-137 (October 2011 - Supersedes all previous editions of form BOEM-0137 which may not be used. Proposed Well/Structure Location

Well or Structure Name/Number (If renaming well or structure, reference previous name): B Subsea Completion

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

Surface Location Bottom-Hole Location (For Wells)

Lease No. OCS- G 32688

Area Name WR

Block No. 460

Blockline Departures (in feet) N/S Departure: 2,624’ FNL

E/W Departure: 832’ FEL

Lambert X-Y coordinates X: 2,311,808’

Y: 9,628,096’

Latitude/ Longitude 26 o 31’ 08.88”

90 o 56’ 46.95”

TVD (Feet): MD (Feet): Water Depth (Feet):-6,965
Anchor Locations for Drilling Rig or Construction Barg e (If anchor radius supp lied above, not necessary) Anchor Name or No. Area Block X Coordinate Y Coordinate Length of Anchor Chain on Seafloor

X = Y =

X = Y =

X = Y =

X = Y =

X = Y =

X = Y =

X = Y =
Paperwork Reduction Ac t of 1995 Statement: The Paperwork Reduction Act of 1995 (44 U.S.C. Chapter 35) requires us to inform you that BOEM collects this information as part of an applicant’s Exploration Plan or Development Operations Coordination Document submitted for BOEM approval. We use the information to facilitate our review and data entry for OCS plans. We will protect proprietary data according to the Freedom of Information Act and 30 CFR 550.197. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently vali d Office of Management and Budget Control Number. The use of th is form is voluntary. The public reporting burden for this form is included in the burden for preparing Exploration Plans a nd Development Operations Coordination Documents. We estimate that burden to average 600 hours per response, or 640 with an accompanying EP (1,000 hours in AKOCSR), or 690 (1,700 in AKOCSR) with an accompanying DPP or DOCD including the time for reviewing instructions, ga thering and maintaining data, and completing and reviewing the forms associated with subpart B. Direct comments regarding the burden estimate or any other aspect of this form to the Information Collection Clearance O fficer, Bureau of Ocean Energy Management, 381 Elden Street, Herndon, VA 20170.

### OCS PLAN INFORMATION FORM (CONTINUED) 

### Include one ConocoPhillips of this pa ge for each proposed well/structure

BOEM Form BOEM-137 (October 2011 - Supersedes all previous editions of form BOEM-0137 which may not be used. Proposed Well/Structure Location

Well or Structure Name/Number (If renaming well or structure, reference previous name): D Subsea Completion

Anchor Radius (if applicable) in feet: Yes No

Surface Location Bottom-Hole Location (For Wells)

Lease No. OCS- G 32678

Area Name WR

Block No. 416

Blockline Departures (in feet) N/S Departure: 4,125’ FNL

E/W Departure: 2,880’ FEL

Lambert X-Y coordinates X: 2,309,760’

Y: 9,642,435’

Latitude/ Longitude 26 o 33’ 31.18”

90 o 57’ 06.97”

TVD (Feet): MD (Feet): Water Depth (Feet):-7,195
Anchor Locations for Drilling Rig or Construction Barg e (If anchor radius supp lied above, not necessary) Anchor Name or No. Area Block X Coordinate Y Coordinate Length of Anchor Chain on Seafloor

X = Y =

X = Y =

X = Y =

X = Y =

X = Y =

X = Y =

X = Y =
Paperwork Reduction Ac t of 1995 Statement: The Paperwork Reduction Act of 1995 (44 U.S.C. Chapter 35) requires us to inform you that BOEM collects this information as part of an applicant’s Exploration Plan or Development Operations Coordination Document submitted for BOEM approval. We use the information to facilitate our review and data entry for OCS plans. We will protect proprietary data according to the Freedom of Information Act and 30 CFR 550.197. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently vali d Office of Management and Budget Control Number. The use of th is form is voluntary. The public reporting burden for this form is included in the burden for preparing Exploration Plans a nd Development Operations Coordination Documents. We estimate that burden to average 600 hours per response, or 640 with an accompanying EP (1,000 hours in AKOCSR), or 690 (1,700 in AKOCSR) with an accompanying DPP or DOCD including the time for reviewing instructions, ga thering and maintaining data, and completing and reviewing the forms associated with subpart B. Direct comments regarding the burden estimate or any other aspect of this form to the Information Collection Clearance O fficer, Bureau of Ocean Energy Management, 381 Elden Street, Herndon, VA 20170.

# ±

®33 3

3 ®33 3

3 Proposed WR460-A Well90°57'0"W90°58'0"W90°59'0"W

26°31'0"N

26°30'0"N

26°29'0"N2,300,0002,305,0002,310,000 9,615,000 9,620,000 9,625,000 9,630,000

0 1,000 2,000 500 Feet

0 250 500 125 Meters Chart Scale 1" = 2,000' 

## Well Location Plat - Public Information Walker Ridge 460 G32688

Location Call N/S Call E/W X Coordinate Y Coordinate Latitude Longitude WD WR460-A SL 2,622ft FNL 2,457ft FEL 2,310,183 9,628,098 26° 31' 09.16"N 90° 57' 04.84"W -6,915

Location Call N/S Call E/W X Coordinate Y Coordinate Latitude Longitude WD WR460-B SL 2,624ft FNL 832ft FEL 2,311,808 9,628,096 26° 31' 08.88"N 90° 56' 46.95"W -6,965 Proposed Location - WR460-A

Proposed Location - WR460-B Proposed WR460-B Well

# ±

®33 3

3

®33 3

3 ®33 3

3 Proposed WR416-D Well90°57'0"W90°58'0"W90°59'0"W

26°34'0"N

26°33'0"N

26°32'0"N2,300,0002,305,0002,310,000 9,630,000 9,635,000 9,640,000 9,645,000

0 1,000 2,000 500 Feet

0 250 500 125 Meters Chart scale 1" = 2,000' 

## Well Location Plat - Public Information Location Call N/S Call E/W X Coordinate Y Coordinate Latitude Longitude WD WR416-D SL 4,125ft FNL 2,880ft FEL 2,309,760 9,642,435 26° 33' 31.18"N 90° 57' 06.97"W -7,195 Proposed Location - WR416-D Walker Ridge 416 G32678

# ±

®33 3

3

®33 3

3 ®33 3

3 - 7 2

0 0

- 7

1 5 0

- 7

1 0

0

- 7 0

5 0

- 7

0

0

0 - 6 9 5 0

- 6 9 0 0

- 6 8 5 0

- 6 8 0 0

- 7 1 0 0 - 7 2 0 0 - 7 0 5 0-7050 - 7 1 5 0

- 7 1 0 0 - 7 0 0 0

- 6 9 5 090°57'0"W90°58'0"W90°59'0"W

2 6 ° 3 4 ' 0 " N

2 6 ° 3 3 ' 0 " N

2 6 ° 3 2 ' 0 " N2,300,0002,305,0002,310,000 9

, 6 3 0

, 0 0 0 9

, 6 3 5

, 0 0 0 9

, 6 4 0

, 0 0 0 9

, 6 4 5

, 0 0 0

0 1

, 0 0 0 2

, 0 0 0 5 0 0 F e e t

0 2 5 0 5 0 0 1 2 5 M e t e r s C h a r t s c a l e 1 " = 2

, 0 0 0 ' 

## Bathymetry Plat P r o p o s e d W R 4 1 6

- D X : 2

, 3 0 9

, 7 6 0 Y : 9

, 6 4 2

, 4 3 5 F E L o f W R 4 1 6 : 2

, 8 8 0 f t F N L o f W R 4 1 6 : 4

, 1 2 5 f t

W

a l k e r R i d g e 4 1 6 G 3 2 6 7 8

Universal Transverse Mercator Zone 15 North, US Feet Spheroid Clarke 1866, Datum North American Datum 1927 Prime Meridian Greenwich False Easting 1,640,416.666667 False Northing 0 Meridian Scale Factor 0.9996 Origin Latitude 0.0000 Origin Longitude -93.0000

# ±

®33 3

3 ®33 3

3 - 7 0

0 0 - 6

9

5

0 - 7 0

5 0

- 6 9 0 0 - 7

1 0

0

- 6

8

5

0 - 7

1 5 0

- 6 8 0 0 - 6 7 5 0 - 7 2 0 0

- 6

7

0 0

- 6 7 5 0 - 6 9 0 0 - 6 8 5 0

- 6 8 5 0 - 6

8

5 0 - 6 8 0 0 - 6 9 5

0

- 7

0

0

0 - 6 8 5 0

- 6 9 5 0

- 6 8 5 0 - 6

8

5

0 - 6 9 5 0

- 6 9 5 0

- 6

8

0

0

- 6 8 0 090°57'0"W90°58'0"W90°59'0"W

2 6 ° 3 1 ' 0 " N

2 6 ° 3 0 ' 0 " N

2 6 ° 2 9 ' 0 " N2,300,0002,305,0002,310,000 9

, 6 1 5

, 0 0 0 9

, 6 2 0

, 0 0 0 9

, 6 2 5

, 0 0 0 9

, 6 3 0

, 0 0 0

0 1

, 0 0 0 2

, 0 0 0 5 0 0 F e e t

0 2 5 0 5 0 0 1 2 5 M e t e r s C h a r t s c a l e 1 " = 2

, 0 0 0 ' P r o p o s e d W R 4 6 0

- A X : 2

, 3 1 0

, 1 8 3 Y : 9

, 6 2 8

, 0 9 8 F E L o f W R 4 6 0 : 2

, 4 5 7 f t F N L o f W R 4 6 0 : 2

, 6 2 2 f t

P r o p o s e d W R 4 6 0

- B X : 2

, 3 1 1

, 8 0 8 Y : 9

, 6 2 8

, 0 9 6 F E L o f W R 4 6 0 : 8 3 2 f t F N L o f W R 4 6 0 : 2

, 6 2 4 f t

W

a l k e r R i d g e 4 6 0 G 3 2 6 8 8



## Bathymetry Plat

Universal Transverse Mercator Zone 15 North, US Feet Spheroid Clarke 1866, Datum North American Datum 1927 Prime Meridian Greenwich False Easting 1,640,416.666667 False Northing 0 Meridian Scale Factor 0.9996 Origin Latitude 0.0000 Origin Longitude -93.0000Online Pa y ment 

### Ste p 3: Confirm Pa y ment 1 | 2 | 3

Pay.gov Tracking Information

Payment Summary



### Thank you. Y our transaction has been successfull y com p leted.

Application Name: BOEM Exploration Plan - BF Pay.gov Tracking ID: 257C499P Agency Tracking ID: 74335790394
Transaction Date and Time: 07/17/2012 18:33 EDT

Address Information

Account Holder Name: j on gaynor

Billing Address: 17407 Saddlebrush tr. Billing Address 2: City: Houston
State / Province: TX Zip / Postal Code: 77095

Country: USA Account Information Card Type: Visa
Card Number: ************3620

Region: Gulf of Mexico

Contact: Bruce Wilcoxon 281- 293-5337 Company Name/No: ConocoPhillips, 00056
Lease Number(s): 32678, 32688, , ,

Area-Block: Walker Ridge WR, 416: , 460: , : , : ,
Surface Locations: 3 Pa y ment Information Payment Amount: $10,326.00

Transaction Date and Time: 07/17/2012 18:33 EDT 

### Pa g e 1 of 1 Pa y

. g ov - Online Pa y ment

7/17/2012 htt p s://www. p a y

. g ov/ p a yg ov/ p a y ments/authorizePlasticCardPa y ment.html

## SECTION B GENERAL INFORMATION

(A) APPLICATIONS AND PERMITS Listed in the table below are additional permits/a pplications to be filed before operations can commence under this EP:

Application/Permit Issuing Agency Status Applications for Permit to Drill BSEE To be submitted

(B) DRILLING FLUIDS Type of Drilling Fluid Estimated Volume of Drilling Fluid to be Used per Well Water-based – Barite, Sodium Chloride Brine, Salt, Xantham Gum, Poly Plus, Lime, Poly Pac UL, Caustic Soda, Defoam X, Greencide 25g 80,000 bbls water based mud (including dilution)

Oil-based (diesel, minerals, oil) 0 bbls Synthetic-based (inter nal olefin, ester) Barite, Synthetic B, Suremul, Surewet, Rheflat, Rhethik, Lime, Calcium Chloride 15,000 bbls synthetic-based mud (including dilution)

(C) NEW OR UNUSUAL TECHNOLOGY No new or unusual technology is proposed for these operations.

(D) BONDING STATEMENT The bond requirements for the activi ties and facilities pr oposed in this EP are satisfied by a $3,000,000.00 area-wide development bond, furnished and maintained according to 30 CFR 256, subpart I; NTL No. 2000-G16, "Guidelines for General Lease Surety Bonds;"

(E) OIL SPILL FINANCIAL RESPONSIBILITY (OSFR) ConocoPhillips Company, BOEM Company Number 00056, will demonstrate oil spill financial responsibility for the facilities proposed in this EP according to 30 CFR Part 553; and NTL No. 2008-N05, "Guidelines for Oil Sp ill Financial Responsibility for Covered Facilities".

(F) DEEPWATER WELL CONTROL STATEMENT ConocoPhillips Company, BOEM Company Number 00056, will have the financial capability to drill a relief well and conduct other emergency well control operations

.
(G) BLOWOUT SCENARIO

• 

### Estimated Initial Flow Rate (bbls/da y): Well Location A - 75,043 bbls/day

• 

### Maximum duration of potential blowout (days): 76 days

ConocoPhillips Company August, 2012 Initial Exploration Plan Page B-1 Walker Ridge Blocks 416 and 460 (OCS-G 32678 and OCS-G 32688)• 

### Total Volume (bbls) (flow rate x duration): Ba sed on the initial flow rate and the expected time to drill a relief well, the total discharge would be 5,703,268 bbls (initial flow rate x duration). However, incorporati ng the expected decline in flow rate over the time it takes to drill a relief well, the total discharge would be 3,956,000 bbls.

• 

### Discussion of potential for well to bridge over (include bac kup to support your assumption): The Thorn well worst case discharge estimate (WCD) has been based on a no bridge over assumption. Therefore the WCD vol ume is the likely rate and vol ume for a catastrophic failure without any restriction in the wellbore. Any bridging would re strict the assumed WCD flow rate and could, in the extreme case, cu rtail flow all together.

• 

### Discussion of likelihood for Surface interventi on to stop blowout; As the Thorn well is planned to be a subsea well, minimal surface well control equi pment will be in place to intervene should the primary subsea well control equipment fail. Neither the riser nor the diverter system beneath the rig floor is designe d to shut in a flowing well. All intervention activities will most likely take place subsea a nd will involve the use of equipment provide by an industry consortium such as Marine Well Containment Company, of which ConocoPhillips is a member.

Relief Well

• 

### Rig type capable of drilling reli ef well at water depth and to TD: The relief well would be drilled by a 5 th 

### or 6 th 

### generation drillship such as the Transocean Discoverer Inspiration (DIN) or the Discoverer Clear Leader (DCL)

• 

### Rig package constraints (if none, make statement to that effect): Both of the planned MODU’s have the ability to drill in th e water depths expected for the planned well and have hook load capacities to drill a relief well.

• 

### Time to acquire rig and move onsite (days): It is estimated the time to notify the current operator of the DIN or DCL, suspend operations (TA), pull riser and transit to the Thorn location would be 16 days.

• 

### Drilling time (days): From rig arrival on loca tion until the blown out we ll is intersected and killed, it is anticipated a total of 60 days would be required.

• 

### Statement whether possibility of using near by platform was considered: No production platforms exist in the area and could not be used to drill a relief well.

Other

• 

### Measures to reduce the likelihood of a blowout: Normal operational procedures followed in the industry will be practiced such as periodic flow checks, surge/swab monitoring and pit monitoring for increase levels which would indicate an influx from the formation into the wellbore (kick). The likelihood of a blowout is related to the number of “kicks” experienced with the goal to minimize the number of kicks taken in the drilling of the well. Mud weights

ConocoPhillips Company August, 2012 Initial Exploration Plan Page B-2 Walker Ridge Blocks 416 and 460 (OCS-G 32678 and OCS-G 32688)ConocoPhillips Company August, 2012 Initial Exploration Plan Page B-3 Walker Ridge Blocks 416 and 460 (OCS-G 32678 and OCS-G 32688) 

### will be employed to maintain sufficient hydrostatic pressure on the open formations to minimize the potential for kicks to occur.

• 

### Measures to enhance ability to conduct effectiv e and early intervention in event of a blowout: ConocoPhillips is a member of the Mari ne Well Containment Company (MWCC), and industry consortium developed to aid its members in the unlik ely event of a major subsea blowout. Membership in this consortium a llows ConocoPhillips to access field proven equipment which is designed to be installed on a blowout well. ConocoPhillips will have in place prior to drilling commencement a “C overed Well Addendum” certificate from MWCC stating MWCC has reviewed the drilling plan and agreeing ConocoPhill ips has access to the appropriate equipment to cap a blown out subsea well.

• 

### Arrangements for drilling relief wells: ConocoPhillips has a Mutual Aid Agreement with the current operators of the two MODU’s which could be used to drill a relief well – depending on which vessel can reach the Thorn location first. Required back up equipment such as subsea wellheads will have been either procured or identified from another operator. Most if not all required tangibles for an emergency well are readily available in the GOM.

• 

### Any other measures: No

Please see Attachment B-1 for additional NTL-2010-N06 calculations and data.

## SECTION C GEOLOGICAL AND GEOPHYSICAL INFORMATION

(A) GEOLOGICAL DESCRIPTION Proprietary Copy Only

(B) STRUCTURE CONTOUR MAPS Current structure contour maps drawn on the to p of each prospective hydrocarbon sand, showing the entire lease block, the locati on of each of the proposed wells, and the locations of geological cross-sections are included as Attachment C-1. ( Proprietary Copy Only )

(C) INTERPRETED 3-D SEISMIC LINE(S) Attached to the Proprieta ry Information ConocoPhill ips of this plan as Attachment C-2 are interpreted 3-D seismic lines. These lines are de pth migrated, annotated with depth scale, and are within 500 feet of the surface locations of the proposed wells. (Proprietary Copy Only)

(D) GEOLOGICAL STRUCTURE CROSS-SECTIONS An interpreted geological structure cross-sect ion showing the location and depth of each proposed well and at least one key horizon and the objective sands labeled using standard biostratigrahic terms are included as Attachment C-3. (Proprietary Copy Only)

(E) SHALLOW HAZARDS REPORT A shallow hazards survey was conducted by Gardline Surveys, Inc. over Walker Ridge Blocks 416, 417, 460 and 461 is being submitted under separate cover.

(F) SHALLOW HAZARDS ASSESSMENT Shallow hazards assessments prepared by Gardline Surveys, Inc. for Walker Ridge Blocks 416 and 460 are included as Attachment C-4.

(G) HIGH-RESOLUTION SEISMIC LINES An annotated seafloor rendering map (Map 1 of 4) prepared by Fugro Geoservices, Inc. is included in Section E as Attachment E-1

.
(H) STRATIGRAPHIC COLUMN A generalized biostratigraphic/lit hostratigraphic column depicting each well from the seafloor to total depth, with each objective horizon labeled, is included as Attachment C-5. (Proprietary Copy Only)

(I) TIME VS DEPTH TABLES Proprietary Copy Only

ConocoPhillips Company August, 2012 Initial Exploration Plan Page C-1 Walker Ridge Blocks 416 and 460 (OCS-G 32678 and OCS-G 32688)

## SECTION D HYDROGEN SULFID E INFORMATION

(A) CONCENTRATION ConocoPhillips does not antic ipate encountering any H 2 

### S during the proposed operations.

(B) CLASSIFICATION Proprietary Data

ConocoPhillips Company August, 2012 Initial Exploration Plan Page D-1 Walker Ridge Blocks 416 and 460 (OCS-G 32678 and OCS-G 32688)

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

(A) CHEMOSYNTHETIC COMMUNITIES REPORT The seafloor disturbing activities proposed in th is plan are in water depths greater than 300 meters (984’). Fugro Geoservices, Inc. was contra cted to provide an assessment of the shallow conditions at the three proposed surface locations. The purpose of the assessment was to address seafloor conditions that may im pact exploratory drilling operati ons within 2,000 feet of the proposed wellsites. ConocoPhillips will avoid all high-density deepwa ter benthic communities by 2,000 feet from each proposed mud and cuttings discharge location and 250 feet from the location of all other seafloor disturbances.

Map Map 1 of 4 prepared by Fugro Geoservices, Inc. entitled "Archaeological, Bathymetry and Seafloor Features Map" is included as Attachment E-1. Using 3-D seismic data, the map depicts bathymetry, seafloor and shallow geological f eatures, surface locations of the proposed wells, and a radius circle of 2,000 feet around each location.

Analysis All seafloor features and areas located within 2,000 feet of each proposed muds and cuttings discharge location have been evaluated for high-density chemosynthe tic communities. The proposed wells will be drilled with a drillship, thus, there are no associated anchors, anchor chains or wire ropes.

Using 3-D seismic information, all seafloor feat ures and areas that co uld be disturbed by the activities proposed in this plan have been identified. The likelihood of these proposed activities disturbing these seafloor and shallow ge ologic features is discussed below:

Walker Ridge Block 416 Well Location D and Wa lker Ridge Block 460 Well Locations A and B do not contain features or areas that could support high-density chemosynthetic or deepwater benthic communities within 2000 feet of any propos ed muds and cuttings discharge location or within 250 feet from the location of other seafloor disturbances.

(B) TOPOGRAPHIC FEATURES MAP Activities proposed in this EP do not fall with in 305 meters (1000 feet) of a topographic “no activity zone”. Therefore, no ma p is required per NTL No. 2008-G04.

(C) TOPOGRAPHIC FEATURES STATEMENT (SHUNTING) All activities proposed under this EP will be conducted outside all Topographic Feature Protective Zones, therefore shunting of drill cuttings and dril ling fluids is not required.

(D) LIVE BOTTOMS (PINNACLE TREND) MAP Walker Ridge Blocks 416 and 460 ar e not located within 61 meters (200 feet) of any live-bottom (pinnacle trend) features . Therefore, no map is re quired per NTL No. 2008-G04.

ConocoPhillips Company August, 2012 Initial Exploration Plan Page E-1 Walker Ridge Blocks 416 and 460 (OCS-G 32678 and OCS-G 32688)

### (E) LIVE BOTTOMS (LOW RELIEF) MAP Walker Ridge Blocks 416 and 460 ar e not located within 30 meters (100 feet) of any live-bottom (low-relief) features. Th erefore, no map is required per NTL No. 2008-G04.

(F) POTENTIALLY SENSITIV E BIOLOGICAL FEATURES Walker Ridge Blocks 416 and 460 are not locate d within 30 meters (100 feet) of potentially sensitive biological features. Therefor e, no map is required per NTL No. 2008-G04.

(G) REMOTELY OPERATED VEHICLE (ROV) SURVEYS BOEM has determined sufficient data has been gathered in Grid Area 11; therefore, ROV surveys will not be conducted prior to or afte r drilling operations for the purpose of biological and physical observations.

(H)THREATENED AND ENDANG ERED SPECIES, CRITICAL HABITAT, AND MARINE MAMMAL INFORMATION Under Section 7 of the Endangered Species Act (ESA) all federal ag encies must ensure that any actions they authorize, fund, or carry out are not li kely to jeopardize the continued existence of a listed species, or destroy or adversely modify its designated critical habitat.

In accordance with, Title 30 CFR 550.221, Subpart B, and furt her outlined in NTL 2008-G04, lessees/operators are required to address site-specific informa tion on the presence of federally listed threatened or endangered species and criti cal habitat designated under the ESA and marine mammals protected under the Marine Mammal Pr otection Act (MMPA) in the area of proposed activities under this plan.

There are five (5) species of s ea turtles that may be found in th e Gulf of Mexico (see table below). NOAA fisheries currently list all five of these turtles as endangered (E) or threatened (T).

Species Scientific Name Status Potential Presence

Critical Habitat Designated in the Gulf of Mexico Lease Area Coastal Sea Turtles Loggerhead carettsa caretta T x x None Green Chelonia mydas T,E x x None Leatherback Dermochelys coriacea E x x None Hawksbill Eretmochelys imbricata E x x None Kemp’s Ridley Lepidochelys kempli E x x None



### In addition, there are 28 species of marine mammal s that may be found in the Gulf of Mexico. The table provided below identifie s the seven (7) species of marine mammals that are listed as endangered or threatened. Currently, there ar e no designated critical habitats for the listed species in the Gulf of Mexico Outer Continental Shelf; however, it is pos sible that one or more of these species could be seen in the area during operations.

ConocoPhillips Company August, 2012 Initial Exploration Plan Page E-2 Walker Ridge Blocks 416 and 460 (OCS-G 32678 and OCS-G 32688)ConocoPhillips Company August, 2012 Initial Exploration Plan Page E-3 Walker Ridge Blocks 416 and 460 (OCS-G 32678 and OCS-G 32688) Species Scientific Name Status Potential Presence Critical Habitat Designated in the Gulf of Mexico Lease Area Coastal

Marine Mammals Sperm Whale Physeter macrocephalus E X -- None West Indian manatee Trichechus manatus latirostris E -- x Florida (Peninsular) Blue Whale Balaenoptera masculus E X -- None Fin whale Balaenoptera physalus E X -- None Humpback whale Megaptera novaeangliae E X -- None North Atlantic right whale Eubalaena glacialis E X -- None Sei whale Balaenopiera borealis E X -- None



### (I) ARCHAEOLOGICAL REPORT An archaeological report, entitled “Archaeo logical Assessment Blocks 416, 417, 460 and 461 Walker Ridge Area Gulf of Mexico" prepared by Fugro Geoservices, Inc. is being submitted under separate cover. Per Fugro, "It is possible that historic shipwreck materials may not be detected by the geophysical instruments or ma y be obscured by modern debris. If wooden planking or other cultural materi als that could represent shipwreck remains are encountered, the BOEM/BSEE archaeologists must be contacted imme diately to provide an assessment of these artifacts, and all operations must cease within 1,000 feet of the exposed object." ConocoPhillips will comply with this re quirement as necessary.

(J) AIR AND WATER QUALITY INFORMATION This EP does not propose activities for which the State of Florida is an affect ed State. Therefore, the discussion required per NTL 2008-G04 is not applicable to this EP.

(K) SOCIOECONOMIC INFORMATION The activities proposed in this plan are not loca ted offshore Florida. Therefore, socioeconomic information required per NTL No. 2008-G 04 is not applicable to this EP.

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JOB NO.: 24125002 POSITIONING BY: STARFIX

INTERPRETATION BY: M. SAMSON
DATE: JUNE 26, 2012 DWG NO.: 24125002.dwg REVISION NO.: 0 DRAFTED BY: C. NOEL



# MAP 1 OF 4 SURVEY DATES: APRIL 8 - 12, 2012

SURVEY VESSEL: FUGRO ENTERPRISE

200 DULLES DRIVE - LAFAYETTE, LOUISIANA 70506 - (337) 237-2636 

# Fugro GeoServices, Inc. 4,000 3,000

FEET 2,000 0 1,000 SCALE = 1:12,000

5,000

GEODETIC DATUM: NAD27

PROJECTION: UTM GRID UNITS: US SURVEY FEET ZONE: U.T.M. 15 (NORTH)

*** IMPORTANT - PLEASE NOTE ***

ANY COMMUNICATION AND/OR POWER CABLES THAT MAY BE PRESENT IN THE AREA CANNOT BE LOCATED BY INSTRUMENTS UTILIZED DURING THIS SURVEY. INQUIRIES SHOULD BE MADE TO INTERESTED PARTIES AS TO THE PRESENCE OF SUCH OBSTRUCTIONS. SHOT POINT & SHOT POINT No.

PROJECT LOCATION

APPLIED ACOUSTIC VELOCITY = HARMONIC MEAN ZERO DATUM = SEA LEVEL CONTOUR INTERVAL = 10 FOOT l l l l l

HACHURES ON DOWNTHROWN SIDE

NORMAL FAULT BURIED 1'-10' FEET BELOW SEAFLOOR, (MINIMUM AVOIDANCE BOUNDARY WHERE APPLICABLE) SIDE SCAN SONAR CONTACT WITH REFERENCE NUMBER
2

10'
l l l l l

HACHURES ON DOWNTHROWN SIDE

FAULT SCARP WITH SEAFLOOR OFFSET IN FEET,

1

1

1 X COORDINATE NUMBER Y COORDINATE

X COORDINATE NUMBER Y COORDINATE X COORDINATE NUMBER Y COORDINATE X COORDINATE NUMBER Y COORDINATE

CHECKED BY: B. DUVAL 

# ARCHAEOLOGICAL, BATHYMETY, & SEAFLOOR FEATURES MAP

BLOCKS 416, 417, 460, & 461

WALKER RIDGE AREA HIGH PROBABILITY CHEMOSYNTHETICS WITH REFERENCE NUMBER

MEDIUM PROBABILITY CHEMOSYNTHETICS REFERENCE NUMBER

LOW PROBABILITY CHEMOSYNTHETICS REFERENCE NUMBER

AREA WITH MOUND-LIKE FEATURES WITH AMBIENT HEIGHT IN FEET

## SECTION F WASTES AND DISCHA RGES INFORMATION

(A) PROJECTED GENERATED WAST ES AND OCEAN DISCHARGES The table provided as Attachment F-1 summarizes information on th e projected solid and liquid wastes likely to be generated by the activities pr oposed in this EP, and t hose wastes that will be discharged to the GOM.

No wastes will be treated, stored or disposed of downhole at the offshore facility (NTL No. 2009-G35).

ConocoPhillips Company August, 2012 Initial Exploration Plan Page F-1 Walker Ridge Blocks 416 and 460 (OCS-G 32678 and OCS-G 32688)(MPOB200didAGENERATED WASTESProjected generated wasteProjected ocean dischargesProjectedDownholeDisposalType of WasteCompositionProAmounjectedt per wellDischargerateDischarge Method Yes or NoWill drilling occur ? If yes, list muds and cuttingsWater-based drillingfluidSeawater and freshwater GLignite, Bariteel, NaCl,80,000 bbls1200 bbl/hrMax RateDisorcharge overboardat seafloorNoCuttings wetted withwater-based fluidCuttings generated while usbased drilling fluiding water-4000 bbls1200 bbl/hrMax RateDisorcharge overboardat seafloorNoCuttings wetted withsynthetic-based fluidCuttings generated while ussynthetic-based drilling fluiding6000 bbls500 bbls / dayDisorcharge overboardat seafloorNoWill humans be there? If yes, expect conventional wasteDomestic wasteGray water900,000 gallons6,000 gal/day(Max POB 200Reandmove floating solidsdischargeNoSanitary wasteyTreated sanitary wastey600,000 allonsg4,000 gal/day(MaxPOB200Chdichargeax slorinate andoverboardNocharge overboarIs there a deck? If yes, there will be Deck DrainageDeck DrainageRainwater and rig washings11,600 bbls100 bbls/dayTreandat for oil and greasedischargeNoWill you conduct well treatment, completion, or workover?Well treatment fluidsNANANANNANon-pollutantcompletions fluidsSalt solutions, weighted brinpolymers and various additives,es8,000 bbls200 bbl/hr Discharge overboard NAWorkover fluidsNANANA NANAMiscellaneous discharges. If yes, only fill in those associated with your activity.Desalinization unitdischargeRejected water from watermaker unit23,200 bbl200 bbls/day Discharge overboard NoBlowout preventer fluidBlend (3% Stack Magic & powater)table335 bbl20bbl/weekDisorcharge overboardat seafloorNoABallast waterUncontaminated seawater umaintain proper draft.sed toAs neededAs needed Discharge overboard NoBilge waterUncontaminated seawater685 bblAs neededDischarge overboard NoExcess cement atseafloorCement slurry1000 bbl500 bbl/dayDisorcharge overboardat seafloorNoFire waterSeawater with no addition ofchemicalsAs needed140,000bbl/dayDischarge overboard NoCooling waterSeawater with no addition ofchemicals16,240,000 bbl140,000bbl/dayDischarge overboard NoWill you produce hydrocarbons? If yes fill in for produced water.Produced waterNANANANNAWill you be covered by an individual or general NPDES permit ?NPDES

## SECTION G AIR EMISSIONS INFORMATION

(A) EMISSIONS WORKSHEETS AND SCREENING QUESTIONS

Screen Procedures for EP’s Yes No Is any calculated Complex Total (CT) Emis sion 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° 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



### There are no existing facilities or activities co -located with the curre ntly proposed activities; therefore, the Complex Total Emissions are the sa me as the Plan Emissions and are provided in the table below.

Drillship

Air Pollutant Plan Emission Amounts

(tons) Calculated Exemption

Amounts

(tons) Calculated Complex Total Emission Amounts (tons) Carbon Monoxide (CO) 459.41 104747.34 459.41 Particular Matter (PM) 61.25 5694.30 61.25 Sulphur Dioxide (SO 2 ) 281.01 5694.30 281.01 Nitrogen Oxides (NO
x ) 2105.62 5694.30 2105.62 Volatile Organic Compounds (VOC) 63.17 5694.30 63.17



### This information was calculated by: Judy Davidson (281) 578-3388 Judy.Davidson@jccteam.com

ConocoPhillips Company August, 2012 Initial Exploration Plan Page G-1 Walker Ridge Blocks 416 and 460 (OCS-G 32678 and OCS-G 32688)

## SECTION H OIL SPILLS INFORMATION

(A) OIL SPILL RESPONSE PLANNING All proposed activities and faciliti es in this EP will be covere d by the Regional OSRP filed by ConocoPhillips Company, BOEM GOM Number 00056, in accordance with 30 CFR 254 and approved on September 17, 2009 and modifications to that plan submitted January, 2011 and October, 2011 (currently pending approval).

(B) SPILL RESPONSE SITES Primary Response Equipment Loca tion Preplanned Staging Location Ingleside, Texas Aransas Pass, Texas Galveston, Texas Port O’Connor, Texas Port Arthur, Texas Freeport, Texas Lake Charles, Louisiana Galveston, Texas Houma, Louisiana Sabine Pass, Texas Belle Chase, Louisiana Lake Charles, Louisiana Venice, Louisiana Cameron, Louisiana Baton Rouge, Louisiana Morgan City, Louisiana Leeville, Louisiana Houma, Louisiana Fort Jackson, Louisiana Fourchon, Louisiana Pascagoula, Mississippi Grand Isle, Louisiana Tampa, Florida Venice, Louisiana Fort Jackson, Louisiana Pascagoula, Mississippi Theodore, Alabama

(C) OSRO INFORMATION Clean Gulf Associates (CGA) and Marine Spi ll Response Corporation (MSRC) are the primary equipment providers for ConocoPhillips in the Gu lf of Mexico region and maintain a dedicated fleet of vessels and other spill response equipm ent permanently located at designated ports. CGA and MSRC have the ability to rapidly mobilize and deploy substantial spill response resources on a 24 hour, 7 days a week basis. MSRC and/or their Spill Team Area Responders (STARs) subcontractors will operate all CGA equipment. In addition ConocoPhillips has a contract with National Response Corporation (NRC) for additiona l equipment. NRC's Independent Contractor Network (ICN) will provide the closest availabl e personnel and additional equipment as needed.

ConocoPhillips’ Oil Spill Response Plan incl udes subsea well containment capability through their Sponsor Membership in the Marine Well Containment Company (MWCC) LLC.

ConocoPhillips Company August, 2012 Initial Exploration Plan Page H-1 Walker Ridge Blocks 416 and 460 (OCS-G 32678 and OCS-G 32688)ConocoPhillips Company August, 2012 Initial Exploration Plan Page H-2 Walker Ridge Blocks 416 and 460 (OCS-G 32678 and OCS-G 32688) 

### (D) WORST-CASE SCENARIO COMPARISON

Category Regional OSRP WCD EP WCD
Type of Activity Drilling Drilling

Facility Location (Area/Block) Garden Banks Block 783 Walker Ridge Block 460

Facility Designation Magnolia TLP Well Well A

Distance to Nearest Shoreline (miles) 149 miles 174 miles

Volume Storage tanks (total) 2,158 barrels NA
Flowlines on Faci lity 200 barrels NA
Uncontrolled blowout 228,313 barrels 75,043 barrels
Total Volume 230,671 barrels 75,043 barrels Type of Oil(s) (crude, condensate, diesel) Crude Oil Crude Oil

API Gravity 40 0 

### 28 0



### ConocoPhillips has determined that the worst-case scenario from the activities pr oposed in this EP does not supersede the worst-case scenario from Regional OSRP. Since ConocoPhillips has the capability to respond to the appropriate wo rst-case spill scenario included in its revised regional OSRP submitted on October 4, 2011, and si nce the worst-case scenario determined for this EP does not replace the appropriate worst- case scenario in our regional OSRP, we hereby certify that ConocoPhillips has th e capability to res pond, to the maximum extent practicable, to a worst-case discharge, or a substantial threat of such a discharge, resulting from the activities proposed in our EP

As a member of CGA, NRCC and MWCC, ConocoPhillips has the capability to respond, to the maximum extent practicable, to a worst-case di scharge, or a substan tial threat of such a discharge, resulting from the activities proposed in the EP.

By letter dated September 1, 2011 ConocoPhillips submitted an OSRP certification statement certifying ConocoPhillip's capab ility to respond to the wors t case discharge and requesting approval to operate for a period not to exceed two years while the Regional OSRP is pending approval. This certification statement was accepted by the BOEM on September 8, 2011. Worst case discharge calculations for Garden Banks Bl ock 783, identified as the Regional OSRP worst case discharge, were approved on March 29, 2012 in the DOCD (Control Number 7506) as additional information to the plan per NTL 2010-N06.

A Spill Response Discussion is included as Attachment H-1.

### ATTACHMENT H-1 SPILL RESPONSE DISCUSSION

For the purpose of NEPA and Coastal Zone Mana gement Act analysis, the largest spill volume originating from the proposed activity would be a well bl owout during drilling operations, estimated to be 75,043 barrels of crud e oil with an API gravity of 28°.

Land Segment and Resource Identification Trajectories of a spill and the probability of it impacting a land segment have been projected utilizing information in the BS EE Oil Spill Risk Analysis Model (OSRAM) for the Central and Western Gulf of Mexico available on the BSEE website. The results are shown in Figure 1. The BSEE OSRAM identifies a 3% proba bility of impact to the s horelines of Cameron Parish, Louisiana within 30 days. Cameron Parish includes the east side of Sabine Lake, Sabine National Wildlife Refuge, Calcasieu Lake, Lacassine Nationa l Wildlife Refuge (inland) and Grand Lake. Cameron Parish also includes the area along the coastline from Sabine Pass to Big Constance Lake in Rockefeller Wildlife Refuge. This region is composed of open public beaches, marshlands and swamps. It serves as a habita t for numerous birds, finf ish and other animals, including several rare, threat ened and endangered species.

Response ConocoPhillips will make every effort to re spond to the Worst Case Discharge (WCD) as effectively as practicable. A de scription of the response equipmen t under contract to contain and recover the WCD is shown in Figure 2.

Using the estimated chemical and physical charact eristics of crude oil, an ADIOS weathering model was run on a similar product from the ADIO S oil database. The results indicate 11% or approximately 8,254 barrels of crude oil would be evaporated/dispersed within 24 hours, with approximately 66,789 barrels remaining.

Spill Response WR 460 A Barrels of Oil

WCD Volume 75,043

Less 11% natural evaporation/dispersion 8,254 Remaining volume 66,789 Daily dispersant capability 7,540 Oil addressed by in-situ burning 3,339



### Figure 2 outlines equipment, personnel, materials and support vessels as well as temporary storage equipment available to respond to a spill of approximately 66,789 barrels. The volume accounts for the amount remaining after evaporatio n/dispersion at 24 hours. The list estimates individual times needed for proc urement, load out, travel time to the site and deployment. Figure 2 also indicates how operations will be supported.

The ConocoPhillips’s Oil Spill Re sponse Plan includes al ternative response te chnologies such as dispersants and in-situ burn. St rategies will be decided by Un ified Command based on the size

### of the spill, weather and potential impacts. If aerial dispersants ar e utilized, 8 sorties (9,600 gallons) from two of the DC-3 ai rcrafts and 4 sorties (8,000 gall ons) from the Basler aircraft would provide a daily dispersant capability of 7,540 barrels. If the conditions are favorable for in-situ burning, the proper approvals have been obt ained and the proper planning is in place, insitu burning of oil may be attempted. Using es timates based on the Deepwater Horizon spill of 2010, up to 5% or approximately 3,339 barrels of the total daily WCD volume could be burned. Slick containment boom would be immediately called out and on-scene as soon as possible. Offshore response strategies may include attemp ting to skim utilizing Clean Gulf Associate's HOSS Barge, and nine Fast Response Units (FRU), along with Marine Spill Response Corporation's (MSRC) Deep Blue Responder, Gulf Coast Responder, Texas Responder, PSV – HOS Centerline, and PSV – HOS Strongline, with a total derated ski mming capacity of 142,723 barrels. Temporary storage asso ciated with skimming equipm ent equals 38,952 barrels. If additional storage is needed, th ree 20,000 barrel storag e barges and a 47,000 barrel storage barge may be mobilized and centrally located to provide temporary storage allowing the skimmers to stay in the area of operations as much as possible. Safety is first priority. Air monitoring will be accomplished and operations deemed safe prio r to any containment/skimming attempts.

If the spill went unabated, s horeline impact in Cameron Pa rish, Louisiana would depend upon existing environmental conditions. Shoreline prot ection would include the use of CGA’s near shore and shallow water skimmers with a tota led derated skimming cap acity of 13,253 barrels. Temporary storage associated with skimming equipment equals 256 barrels. If additional storage is needed, a 23,000 barrel storage barge may be mobilized and centrally located to provide temporary storage allowing the skimmers to stay in the area of operations as much as possible. Onshore response may include the deployment of shoreline boom on beach areas, or protection and sorbent boom on vegetated areas. A Master Service Agreement with ES&H will ensure access to 40,000 feet of 18” shoreline protection boom. Figure 2 outlines individual times needed for procurement, load out, travel time to the site and deployment. Strategies would be based upon surveillance and real time trajectories that depict areas of potential impact given actual sea and weather conditions. The State of Louisiana Initial Oil Spill Response Plan for Cameron Parish and Unified Command would be consulted to ensure that environmental and special economic resources would be correctly identified and prioritized to ensure optimal protection. Shoreline protect ion strategies depict the protecti on response modes applicable for oil spill clean-up operations. The State of Louisiana Initial Oil Spill Response Plan provides detailed shoreline protection strategies fo r this area, and it describes nece ssary action to ke ep the oil spill from entering Louisiana’s coastal wetlands, based on the assumption that re moval of the released oil will be much easier and less damaging to fragile coastal ecosystem s if done in the open waters of the Gulf of Mexico. Supervisory pers onnel have the option to modify the deployment and operation of equipment allowing a more eff ective response to site-specific circumstances. ConocoPhillips’s contract Spill Management Team holds a copy of the Stat e of Louisiana Initial Oil Spill Response Plan.

Based on the anticipated WCD scen ario, ConocoPhillips can be onsit e with contracted oil spill recovery equipment with adequate respons e capacity to contain and recover surface hydrocarbons, and prevent land impact, to the maximum extent practicable, within an estimated 45 hours (based on the equipment’s Effectiv e Daily Recovery Capacity (EDRC)).

### Initial Response Considerations Actual actions taken during an oil spill response will be based on many factors which include but are not limited to:

• Weather

• Equipment and materials availability

• Ocean currents and tides

• Location of the spill

• Product spilled

• Amount spilled

• Environmental risk assessments

• Trajectory and product analysis

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

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

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

• Information will be confirmed

• An assessment will be made and initial objectives set

• Oil Spill Response Organizations (OSRO) a nd appropriate agencies will be notified

• ICS 201, Initial Report Form will be completed

• Initial Safety plan will be written and published

• Unified Command will be established

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

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

o On-site command and control established

Offshore Response Actions

Equipment Deployment Surveillance

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

• Provide trained observer to pr ovide on site status reports

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

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

• Continual monitoring of vessel assets using vessel monitoring systems

### Dispersant application assets

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

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

• Gain FOSC approval for use of dispersants on the surface

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

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

• Confirm dispersant availability fo r current and long range operations

• Start ordering dispersa nt stocks required for expected operations

Containment boom

• Call out early and expedite deployment to be on scene as soon as possible

• Ensure boom handling and mooring equipment is deployed with boom

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

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

Dedicated offshore skimming systems General

• Deployed to the highest concentration of oil

• Assets deployed at safe distance from aer ial dispersant and in-situ burn operations

CGA HOSS Barge

• Use in areas with heaviest oil concentrations

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

CGA FRUs

• To the area of the thickest oil

• Use as far off-shore as allowed

• VOOs 140’ – 180’ in length

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

MSRC Oil Spill Response Vessels (OSRV)

• Use in areas with heaviest oil concentrations

• Use as far off-shore as allowed

MSRC Responders

• Use in areas with heaviest oil concentrations

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

### Storage Vessels

• Establish availability of CGA contracted assets

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

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

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

Vessels of Opportunity (VOO)

• Use ConocoPhillips’s contracted resources as applicable

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

• Acquire additional resources as needed

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

• Expect mission specific and sa fety training to be required

• Plan with the US Coast Guard for vessel inspections

In-situ Burn assets

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

• Determine availability of fire boom and selected ignition systems

• Start ordering fire boom stocks required for expected operations

• Contact boom manufacturer to provide training if required

• Determine assets to perform on water operation

• Build operations into safety plan

• Conduct operations in accordance with an approved plan

### Near Shore Response Actions

Timing

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

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

• Outfitting of VOOs for specific missions

• Deployment of assets based on actual movement of oil

Considerations

• Water depth, vessel draft

• Shoreline gradient

• State of the oil

• Use of VOOs

• Distance of surf zone from shoreline

Equipment Deployment Surveillance

• Provide trained observer to direct skimming operations

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

• Continual monitoring of vessel assets

Dispersant Use

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

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

Vessel Deployment Dedicated Near Shore skimming systems

• Fast Response Vessels (FRV)

• Egmopol and Marco Shallow Water Skimmer (SWS)

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

VOO

• Use ConocoPhillips’s contracted resources as applicable

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

• Acquire additional resources as needed

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

• Expect mission specific and sa fety training to be required

• Plan with the US Coast Guard for vessel inspections

• Operate with aerial spotter directing systems to oil patches

### Shoreline Protection Operations Response Planning Considerations

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

• Time to acquire personnel and eq uipment and their availability

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

Actions Placement of boom

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

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

o Trajectories

o Weather forecast

o Oil Impact forecast

o Verified spill movement

o Boom, manpower and vessel (shallow draft) availability

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

Beach Preparation Considerations and Actions

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

• Shoreline Cleanup and Assessment Team Reports and recommendations

• Determination of Archeological site s and gaining authority to enter

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

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

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

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

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

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

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

• Earthen berms and shoreline protection boom may be considered to protect sensitive inland areas

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

recovery.

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

Boom 3 foot seas, 20 knot winds Dispersants Winds more than 25 knots Visibility less than 3 nautical miles Ceiling less than 1,000 feet.
FRU 8 foot seas HOSS Barge/OSRB 8 foot seas Koseq Arms 8 foot seas OSRV 4 foot seas

### Environmental Conditions in the Gulf of Mexico Louisiana is situated between the easterly and westerly wind belts, and therefore, experiences westerly winds during the wint er and easterly winds in the summer. Average wind speed is generally 14-15 mph along the coast. Wave he ights average 4 and 5 feet. However, during hurricane season, Louisiana has recorded wave heights ranging from 40 to 50 feet high and winds reaching speeds of 100 mph. Because much of southern Louisiana lies below sea level, flooding is prominent.

Surface water temperature ranges between 70 and 80  ̊ F during the summer months. During the winter, the average temperatur e will range from 50 and 60  ̊ F.

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

### FIGURE 1 TRAJECTORY BY LAND SEGMENT

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

Area/Block OCS-G Launch Area Land Segment and/or Resource Conditional Probability (%) within 30 days

Drill and complete 3 wells

WR 460 A

174 miles from shore G32688 C047 Matagorda, TX Brazoria, TX Galveston, TX Jefferson, TX Cameron, LA Vermilion, LA Terrebonne, LA Plaquemines, LA 1 1 2 1 3 1 1 1WCD Scenario– BASED ON WELL BLOWOUT DURING DRILLING OPERATIONS(174 miles from shore)66,789 bbls of crude oil (Volume considering natural weathering)API Gravity 28°FIGURE 2 – Equipment Response Time to WR 460 ADispersants/SurveillanceDispersant/SurveillanceDispersantCapacity (gal)StorageCapacityPersonsReq.FromHrs to ProcureHrs toLoadoutTravel tositeTotal HrsCGABasler 67T2000NA2Houma111.13.1ASIDC 31200NA2Houma111.43.4DC 31200NA2Houma111.43.4Aero CommanderNANA2Houma111.13.1Offshore ResponseOffshore EquipmentPre-Determined StagingEDRCStorageCapacityVOOPersonsRequiredFromHrs toProcureHrs toLoadoutHrs toGOMTravel toSpill SiteHrs toDeployTotalHrsCGAHOSS Barge4300040003 Tugs8Harvey70521.3134.3Recovered Oil StoragePre-Determined StagingEDRCStorageCapacityVOOPersonsRequiredFromHrs toProcureHrs toLoadoutHrs toGOMTravel toSpill SiteHrs toDeployTotalHrsEnterprise Marine Services LLC (available through contract with CGA)CTCo 2604NA200001 Tug6Amelia412423.75144.75CTCo 2605NA200001 Tug6Amelia412423.75144.75CTCo 2606NA200001 Tug6Amelia412423.75144.75CTCo 5001NA470001 Tug6Amelia412423.75144.75Offshore EquipmentPre-determined StagingEDRCStorageCapacityVOOPersonsRequiredFromHrs toProcureHrs toLoadoutHrs toGOMTravel toSpill SiteHrs toDeployTotalHrsMSRCDeep Blue ResponderLFF 100 Brush + OSRV6,600’ 44” Sea Sentry II Boom660’ 67” LAMOR180864000NA14Fourchon2017.4111.4PSV – HOS Centerline1 Crucial Disk 88/301,320’ EFC (cont inflate)1112210626NA14Fourchon1212115.4141.4PSV – HOS Strongline1 Crucial Disk 88/301,320’ EFC (cont inflate)1112210626NA14Fourchon1212115.4141.4Gulf Coast ResponderTransrec 350 + OSRV5,280’ 44” Sea Sentry II Boom2,640’ 67” LAMOR105674000NA14Lake Charles20110.8114.8Texas ResponderTransrec 350 + OSRV4,620’ 44” Sea Sentry II Boom3,300’ 67” LAMOR105674000NA14Galveston20112116Staging Area: FourchonOffshore EquipmentPreferred StagingEDRCStorageCapacityVOOPersonsReq.FromHrs toProcureHrs toLoadoutTravel toStagingTravel toSiteHrs toDeployTotalHrsCGAFRU (1) + 100 bbl Tank (1)42511001 Utility6Harvey122.7515.4122.15FRU (1) + 100 bbl Tank (2)42512001 Utility6Morgan City122.515.4121.9FRU (1) + 100 bbl Tank (2)42512001 Utility6Galveston12715.4126.4FRU (1) + 100 bbl Tank (2)42512001Utility6Ingleside129.515.4128.9FRU (1) + 100 bbl Tank (2)42512001Utility6Lake Charles12415.4123.4FRU (2) + 100 bbl Tank (4)85024002 Utility12Venice12415.4123.4FRU (2) + 100 bbl Tank (4)85024002 Utility12Leeville12.515.4119.9Offshore EquipmentPreferred StagingEDRCStorageCapacityVOOPersonsReq.FromHrs toProcureHrs toLoadoutTravel toStagingTravel toSiteHrs toDeployTotalHrsCGA42” Auto Boom (5000’)NANA10 Crew20Galveston12715.4126.442” Auto Boom (10000’)NANA20 Crew40Harvey122.7515.4122.1542” Auto Boom (2500’)NANA6 Crew12Ingleside129.515.4128.942” Auto Boom (5000’)NANA10 Crew20Lake Charles12415.4123.442” Auto Boom (2500’)NANA6 Crew12Pascagoula12415.4123.41000’ Hydro-Fire BoomNANA8 Utility40Harvey142.515.4628.9MSRC44” Sea Sentry II Boom(2860’)NANA6 Crew12Ingleside129.515.4128.944” Sea Sentry II Boom(4290’)NANA10 Crew20Galveston12715.4126.444” Sea Sentry II Boom(6679’)NANA10 Crew20Lake Charles12415.4123.444” Sea Sentry II Boom(1980’)NANA6 Crew12Fort Jackson123.7515.4123.1544” Sea Sentry II Boom(3190’)NANA10 Crew20Pascagoula12415.4123.42000’ Hydro-Fire BoomNANA16 Utility80Lake Charles14415.4630.4Nearshore ResponseNearshore Recovered Oil StoragePre-Determined StagingEDRCStorageCapacityVOOPersonsRequiredFromHrs toProcureHrs toLoadoutHrs toGOMTravel toSpill SiteHrs toDeployTotalHrsEnterprise Marine Services LLC (available through contract with CGA)CTCo 2607NA230001 Tug6Amelia412415136Staging Area: CameronNearshore and InlandSkimmers With StagingEDRCStorageCapacityVOOPersonsReq.FromHrs toProcureHrs toLoadoutTravel toStagingTravel toDeploymentHrs toDeployTotalHrsCGASWS Egmopol3000100NA3Galveston123.5208.5SWS Egmopol3000100NA3Houma124209SWS Marco358834NA3Houma124209SWS Marco358820NA3Lake Charles121206Rope Mop77203Belle Chasse124.5209.5Shoreline ProtectionStaging Area: CameronShoreline ProtectionBoomVOOPersonsReq.Storage/WarehouseLocationHrs toProcureHrs toLoad OutTravel toCameronTravel toDeploymentHrs toDeployTotal HrsES&H (available through MSA)20,000’ 18” Shoreline Boom8 Crew20New Iberia, LA.5.52.5265.520,000’ 18” Shoreline Boom8 Crew20Belle Chasse, LA.5.54.5267.5Beach BoomEDRCStorageCapacityVOOPersonsReq.FromHrs toProcureHrs toLoadoutTravel toStagingTravel toDeploymentHrs toDeployTotalHrsCGABeach Boom (2000’)NANANA6Galveston123.5129.5Beach Boom (1000’)NANANA4Ingleside1261212Beach Boom (2000’)NANANA6Pascagoula125.51211.5Wildlife ResponseEDRCStorageCapacityVOOPersonsReq.FromHrs toProcureHrs toLoadoutTravel toStagingTravel toDeploymentHrs toDeployTotalHrsCGAWildlife Support TrailerNANANA2Houma1241210Bird Scare Guns (24)NANANA2Belle Chasse124.51210.5Bird Scare Guns (12)NANANA2Galveston123.5129.5Bird Scare Guns (24)NANANA2Houma1241210Bird Scare Guns (12)NANANA2Ingleside1261212Bird Scare Guns (24)NANANA2Lake Charles121127Bird Scare Guns (24)NANANA2Pascagoula125.51211.5Response AssetTotalOffshore EDRC142,723Offshore Recovered Oil Storage145,952Nearshore / Shallow Water EDRC13,253Nearshore / Shallow Water Recovered Oil Storage23,256

## SECTION I ENVIRONMENTAL MONITORING INFORMATION

(A) MONITORING SYSTEMS ConocoPhillips has a number of safety systems and practices in place to mi nimize the occurrence and subsequent impact of accidental releases. The system s are designed to alert operators with alarms in the event of a release.

ConocoPhillips employees, contractors, and subcontra ctors are responsible for maintaining a vigilant watch for oil spill discharges of any magnitude from ConocoPhillips facilities and operations. Any person who observes or becomes aware of an oil sp ill shall immediately repor t the incident to the person in charge of the facility. The Person in Ch arge must then immediately notify the “On Call” Qualified Individual/Incident Commander.

Facility operators are trai ned to respond to the various system alarms in order to identify and control releases immediately. The routine re sponsibilities that ensure oil spi lls will be detected and mitigated as soon as possible by facility operation personnel may include, but are not limited to the following:

• 

### Daily visual monitoring of all discharge points to ensure no presence of oil on the water.

• 

### Routine walk-through and monitoring of equipment and vessel pressures, temp eratures, levels, etc. to ensure proper operation of a ll equipment at the facility.

• 

### Immediate response to alarms and signals that may indicate a possible release of oil.

• 

### Identify and shut off the source as soon as possible, taking safety into account.

• 

### Notify the ConocoPhillips Person in Charge as soon as possible to mitigate spill event.

Additional monitoring will be conduc ted during routine helicopter fli ghts to the facility and by routine marine vessels traveling to and from the facility. As stated above, any spills or sheens observed by these routine activities will be reported to the facility Person in Charge.

Eddy or Loop currents will be monitored as pe r NTL 2009-G02 via Horizon Marine Services. ConocoPhillips subscribes to Impact Weather Se rvice which provides real -time weather conditions such as tropical depressions, storms a nd/or hurricanes entering the Gulf.

(B) INCIDENTAL TAKES To mitigate against incidental takes of protected species, all activities will be conducted in accordance with the following Notices to Lessees:

• NTL No. 2012-JOINT-G01, “Vessel Strike Avoi dance and Injured/Dead Protected Species Reporting”

• BSEE NTL No. 2012-G01, “Marine Trash and Debris Awareness and Elimination”

• NTL-No. 2012-JOINT-G02, “Implementation of Seismic Survey Mitigation Measures and Protected Species Observer Program”

Operations proposed in this plan wi ll not use explosives or an air gun. An auxiliary no tification will be filed in support of a borehole seismic survey (VSP). Trained observers and a ramp-up procedure will be used per NTL No. 2012-JOINT-G02.

ConocoPhillips Company August, 2012 Initial Exploration Plan Page I-1 Walker Ridge Blocks 416 and 460 (OCS-G 32678 and OCS-G 32688)ConocoPhillips Company August, 2012 Initial Exploration Plan Page I-2 Walker Ridge Blocks 416 and 460 (OCS-G 32678 and OCS-G 32688) 

### (C) FLOWER GARDEN BANKS NATIONAL MARINE SANCTUARY Walker Ridge Blocks 416 and 460 are not located in the Flower Garden Banks National Marine Sanctuary; therefore, provisions fo r monitoring the impact of an oil spill are not required in this EP.

## SECTION J LEASE STIPULATIONS INFORMATION

Exploration activities are subject to the following stipulation attached to Leases OCS-G 32678 and OCS-G 32688 (Walker Ridge Blocks 416 and 460).

Marine Protected Species Lease Stipulation No. 8 is meant to reduce the potential taking of mari ne protected species. ConocoPhillips will operate in accordance with NTL 2012-JO INT-G01 to minimize the risk of vessel strikes to protected species, report observations of injured or dead protected species, and prevent the intentional and/or ac cidental introduction of debris into the marine environment.

ConocoPhillips Company August, 2012 Initial Exploration Plan Page J-1 Walker Ridge Blocks 416 and 460 (OCS-G 32678 and OCS-G 32688)

### SECTION K ENVIRONMENTAL MITIGATION MEASURES INFORMATION

(A) INCIDENTAL TAKES Mitigation measures and monitoring for incidental takes of protected speci es will be conducted in accordance with the following Notices to Lessees, as applicable, to avoid or minimize impacts to any of the species listed in the ESA as a result of the operati ons conducted herein:

• NTL No. 2012-JOINT-G01, “Vessel Strike Avoi dance and Injured/Dead Protected Species Reporting”

• BSEE NTL No. 2012-G01, “Marine Trash and Debris Awareness and Elimination”

• NTL No. 2012-JOINT-G02, “Implementation of Seismic Survey Mitigation Measures and Protected Species Observer Program”

ConocoPhillips Company August, 2012 Initial Exploration Plan Page K-1 Walker Ridge Blocks 416 and 460 (OCS-G 32678 and OCS-G 32688)

### SECTION L SUPPORT VESSELS* AND AI RCRAFT INFORMATION

(A) GENERAL The most practical, direct route from the shorebas e as permitted by weather a nd traffic conditions will be utilized.

Type Maximum Fuel Tank Capacity Maximum Number in Area at Any Time Trip Frequency or Duration Supply Vessel (PSV) 200,000 gallons 2 2 Trips/Week
Fast Supply Vessel (FSV) 25,000 gallons 1 3 Trips/Week Helicopter 760 gallons 1 10/Week

(B) DIESEL OIL SUPPLY VESSELS Fuel for the drilling unit will be tran sported via a supply vessel as follows:

Size of Fuel Supply Vessel Capacity of Fuel Supply Vessel Frequency of Fuel Transfers Route Fuel Supply Vessel Will Take 240’ minimum 200,000 gallons Every 20 days Most direct route from Fourchon, LA *Please note the actual vessels have not yet been contracted.

(C) SOLID AND LIQUID WASTE TRANSPORTATION Table 2, “ Wastes You Will Transport and/or Dispose of Onshore” is included in this section as Attachment L-1.

(D) VICINITY MAP Enclosed as Attachment L-2 is a vicinity map showing the locat ion of the activities proposed herein relative to the shoreline w ith the distance of the proposed activiti es from the shoreline and the primary route(s) of the support ve ssels and aircraft that will be used when trav eling between the onshore support facilities a nd the dril ling unit.

ConocoPhillips Company August, 2012 Initial Exploration Plan Page L-1 Walker Ridge Blocks 416 and 460 (OCS-G 32678 and OCS-G 32688)Solid and Liquid WastestransportationType of Waste Composition Transport Method Name/Location of Facility Amount/well Disposal MethodWill drilling occur ? If yes, fill in the muds and cuttings.116 day wellSpent Synthetic-based drilling fluid or mudSBM drilling fluids with highwater %Internal mud tanks on marine vesselMI-SWACO, Port FourchonFacility5,000 bblsReconditioned atmudplantSynthetic-based drilling fluid or mudUsed synthetic baseddrillingfluidsInternal mud tanks on marine vesselMI-SWACO, Port FourchonFacility10,000 bbls Stored at mud plantOil-based drilling fluid or mudNANANANANACuttings wetted with Water-based fluidNA NA NA NA NACuttings wetted with Synthetic-based fluidNANANANANACuttings wetted with oil-based fluidsNA NA NA NA NAWill you produce hydrocarbons? If yes fill in for produced sandATTACHMENT L-1WASTES TRANSPORTED TO SHOREWaste Disposal EstimatesProjected generated wasteWillyouproducehydrocarbons?Ifyesfillinforproducedsand.Produced sandNA NA NA NA NATrash and debris (non-recyclable)Non-recyclable non-hazardous trashand debrisStorage bins on supply boat Newpark, Port Fourchon 120,000 lbs BurialTrash and debris (recyclable)Recyclable non-hazardoustrash and debrisBags or storage bins on supply boat Newpark, Port Fourchon 144,000 lbs RecycleUsed oilUsed oil, oil filters, rags,pads, empty drums, cookingoilVendor supplied DOT storage binson supply vessel then trucked tovendor facility.Newpark, Port Fourchon 60,000 lbs Burial/burnTank wash waterClean supply vessel tanks Truck Newpark, Port Fourchon 1,000 bblsInjection in disposalwellChemical product wastesPaints, solvents, unusedchemicals, etc.Vendor supplied DOT storage binson supply vessel then trucked tovendor facility.Newpark, Port Fourchon 6,000 lbs BurialWill you have additional wastes that are not permitted for discharge? If yes, fill in the appropriate rows.! ! ! ! ! !

! !

! ! ! ! ! ! ! ! ! !

! ! ! ! ! ! ! !

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W R 4 6 0

: ~ 1 8 5

. 5 M i l e s t o F o u r c h o n

, L A

W R 4 6 0

### SECTION M ONSHORE SUPPORT FACILITIES INFORMATION

(A) GENERAL Per NTL No. 2008-G04, the following ta ble reflects the onshore facilities to be u tilized to provide supplies and services support for the activ ities proposed in this Exploration Plan.

The onshore support bases for water and air transporta tion will be located in existing terminals in Fourchon and Amelia, Louisiana.

Name of Shorebase Location Existing/New/Modified Chouest Port (C-Port) Port Fourchon, LA Existing PHI Heliport Amelia, LA Existing MI SWACO Port Fourchon, LA Existing

Newpark Port Fourchon, LA Existing

(B) SUPPORT BASE CONSTRUCTION OR EXPANSION There will be no new construction of an onshore s upport base, nor will an existing support base be expanded as a result of the operations proposed in this Exploration Plan.

(C) WASTE DISPOSAL Table 2, “Wastes You Will Transport and/or Dispose of Onshore” is included in Appendix L as Attachment L-1.

ConocoPhillips Company August, 2012 Initial Exploration Plan Page M-1 Walker Ridge Blocks 416 and 460 (OCS-G 32678 and OCS-G 32688)

### SECTION N COASTAL ZONE MANAGEMENT ACT (CZMA) INFORMATION

Relevant enforceable policies were considered in certifying consistency for Louisiana. A certificate of Coastal Zone Management Consistency for the state of Louisiana is enclosed as Attachment N-1

.

ConocoPhillips Company August, 2012 Initial Exploration Plan Page N-1 Walker Ridge Blocks 416 and 460 (OCS-G 32678 and OCS-G 32688)

### SECTION O ENVIRONMENTAL IMPACT ANALYSIS (EIA)

ConocoPhillips Company August, 2012 Initial Exploration Plan Page O-1 Walker Ridge Blocks 416 and 460 (OCS-G 32678 and OCS-G 32688)

# Environmental Impact Analysis

INITIAL EXPLORATION PLAN
for Walker Ridge Block 416 (OCS

- G 32678) Walker Ridge Block 460 (OCS

- G 32688)

Offshore Louisiana

August 2012

Prepared for:

Bruce Wilcoxon
HSE Lead – Gulf of Mexico Exploration ConocoPhillips Company 600 North Dairy Ashford Houston, Texas 77079

- 1175 Telephone: (281) 295

- 5337

Prepared by:

CSA International, Inc.
8502 SW Kansas Avenue

Stuart, Florida 34997 Telephone: (772) 219

- 3000Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page ii 

## Contents

Page



### Introduction

................................................................................................................ 1

A. Impact

- Producing Factors

....................................................................................... 5

A.1 Drilling Rig Presence (including noise and lights)

........................................................................... 5
A.2 Physical Disturbance to the Seafloor

.............................................................................................. 5
A.3 Air Pollutant Emissions

................................................................................................................... 5
A.4 Effluent Discharges

......................................................................................................................... 8
A.5 Water Intake

................................................................................................ ................................... 8
A.6 Onshore Waste Disposal

................................................................................................................. 8
A.7 Marine Debris

................................................................................................ ................................ . 8
A.8 Support Vessel and Helicopter Traffic

............................................................................................ 9
A.9 Accidents

................................................................................................ ........................................ 9
A.9.1 Types of Accidents Evaluated

............................................................................................. 9
A.9.2 Small Fuel Spill

.................................................................................................................... 9
A.9.3 Crude Oil Spill (Worst Case Discharge)

............................................................................. 11
A.9.4 Other Accidents Not Analyzed in Detail

............................................................................ 14



### B. Affected Environment

........................................................................................... 15

C. Impact Analysis

..................................................................................................... 17

C.1 Physical/Chemical Environment

................................................................................................... 17
C.1.1 Air Quality

......................................................................................................................... 17
C.1.2 Water Quality

.................................................................................................................... 19
C.2 Seafloor Habitats and Biota

.......................................................................................................... 22
C.2.1 Soft Bottom Benthic Communities

................................................................................... 22
C.2.2 High

- Density Deepwater Benthic Communities

............................................................... 24
C.2.3 Designated Topographic Features

.................................................................................... 26
C.2.4 P innacle Trend Area Live Bo t toms

.................................................................................... 26
C.2.5 Live Bottom/Low Relief

..................................................................................................... 27
C.3 Threatened, Endangered, and Protected Species and Critical Habitat

........................................ 27
C.3.1 Sperm Whale (Endangered)

.............................................................................................. 29
C.3.2 West Indian Manatee (Endangered)

................................................................................. 32
C.3.3 Endangered Mysticete Whales

......................................................................................... 33
C.3.4 Non

- Endangered Marine Mammals (Protected)

.............................................................. 34
C.3.5 Sea Turtles (Endangered/Threatened)

............................................................................. 37
C.3.6 Piping Plover ( Threatened)

............................................................................................... 40
C.3.7 Whooping Crane (Endangered)

........................................................................................ 42
C.3.8 Gulf Sturge on (Threatened)

.............................................................................................. 43
C.3.9 Beach Mice (Endangered)

................................................................................................ . 43
C.4 Coastal and Marine Birds

.............................................................................................................. 44
C.4.1 Marine Birds

...................................................................................................................... 44
C.4.2 Shorebirds and Coastal Nesting Birds

............................................................................... 47

## Contents (C ontinued)

Page

Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page iii C.5 Fisheries Resources

...................................................................................................................... 49
C.5.1 Pelagic Communities and Ichthyoplankton

...................................................................... 49
C.5.2 Essential Fish Habitat

........................................................................................................ 52
C.6 Archaeological Resources

............................................................................................................. 55
C.6.1 Shipwreck Sites

................................................................................................................. 55
C.6.2 Prehistoric Archaeological Sites

........................................................................................ 56
C.7 Coastal Habitats and Protected Areas

.......................................................................................... 56
C.8 Socioeconomic and Other Resources

........................................................................................... 59
C.8.1 Recreational and Commercial Fishing

.............................................................................. 59
C.8.2 Public Health and Safety

................................................................................................... 61
C.8.3 Employment and Infrastructure

....................................................................................... 62
C.8.4 Recreation and Tourism

.................................................................................................... 63
C.8.5 Land Use

............................................................................................................................ 64
C.8.6 Other Marine Uses

............................................................................................................ 65
C.9 Cumulative Impacts

...................................................................................................................... 65



### D. Environmental Hazards

......................................................................................... 66

D.1 Geologic Hazards

.......................................................................................................................... 66
D.2 Severe Weather

............................................................................................................................ 67
D.3 Currents and Waves

..................................................................................................................... 67



### E. Alternatives

.......................................................................................................... 67

F. Mitigation Measures

............................................................................................. 67

G. Consultation

......................................................................................................... 67

H. Preparers

.............................................................................................................. 68

I. References

............................................................................................................. 68Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page iv 

## List of Tables

Table Page

1 Notices to Lessees and Operators (NTLs) applicable to this Environmental Impact Analysis (EIA)

......................................................................................................................... 3

2 Matrix of impact

- producing factors and affected environmental resources

........................ 6

3 Conditional probabilities of a spill in the lease area contacting shoreline segments (From: Ji et al., 2004

............................................................................................................ 12

4 Benthic community data from stations near the lease area (Data from: Wei, 2006; Rowe and Kennicutt, 2009)

................................................................................................ . 22

5 Federally listed endangered and thr eatened species potentially occurring in the lease area and along the northern Gulf Coast

.................................................................... 28

6 W ildlife refuges, wilderness areas, and State and National parks wi thin the geographic range of the potential shoreline contacts within 30 days following an oil spill in the lease area

...................................................................................................... 58



## List of Figures

Figure Page

1 Vicinity map for the lease area

.............................................................................................. 2

2 Bathymetric map of Walker Ridge (WR) Blocks 460 and 416 showing the surface locations of proposed wells

................................................................................................ . 16

3 Location of selected environmental features in re lation to the lease area

........................ 41Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page v 

## Acronyms and Abbreviations

ADIOS 2 Automated Data Inquiry for Oil Spills 2 bbl barrel
BLPD barrels of liquid per day
BOEM Bureau of Ocean Energy Managem ent
BOEMRE Bureau of Ocean Energy Managem ent, Regulation and Enforcement
BOP blowout preventer
BOPD barrels of oil per day
BSEE Bureau of Safety and Environmental
Enforcement
CH 4 methane
CO carbon monoxide
CO 2 carbon dioxide
CFR Code of Federal Regulations
CGA Clean Gulf Associates
COP ConocoPhillips Company
DP dynamically positioned
DPS distinct population segment
EA Environmental Assessment
EFH Essential Fish Habitat
EIA Environmental Impact Analysis
EIS Environmental Impact Statement
ERMA Environmental Response Management Application
ESA Endangered Species Act
FAD fish

- attracting device

FR Federal Register
Gardline Gardline Surveys Inc.
GMFMC Gulf of Mexico Fishery Manage ment Council
H 2 S hydrogen sulfide
HAPC Habitat Area of Particular Concern

EP Exploration Plan
IPF impact

- producing factor
MARPOL International Convention for the Prevention of Pollution from Ships MMC Marine Mammal Commission
MMPA Marine Mammal Protection Act
MMS Minerals Management Service
MMSCFD million standard cubic feet per day
MSRC Marine Spill Response Corporation
MWCC Marine Well Containment Company NAAQS National Ambient Air Quality Standards
NMFS National Marine Fisheries Service
NOAA National Oceanic and Atmospheric
Administration
NO 2 nitrogen dioxide
NO x nitrogen oxides
NPDES National Pollutant Discharge Elimination System
NPS National Park Service
NRDA Natural Resource Damage Assessment
NTL Notice to Lessees and Operators
NWR National Wildlife Refuge
OCS Outer Continental Shelf
OCSLA Outer Continental Shelf Lands Act
OSRA Oil Spill Risk Analysis
OSHA Occupational Safety and Health
Administration
OSRP Oil Spill Response Plan PAH p olycyclic a romatic h ydrocarbon

PM particulate matter
SBM synthetic

- based mud
SO x sulfur oxides
SOPEP Shipboard Oil Pollution Emergency Plan
SWSS Sperm Whale Seismic Study
USCG U.S. Coast Guard
USEPA U.S. Environmental Protection Agency
USFWS U

. S. Fish and Wildlife Service
VOC volatile organic compound
WCD worst case discharge
WR Walker RidgeWalker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 1 

## Introduction

ConocoPhillips (COP ) is submitting a n Initial Exploration Plan (EP) to the Bureau of Ocean Energy Management ( BOEM 1 ) for Walker Ridge (WR) Blocks 416 and 460

. Under the Initial EP, COP plans to drill up to three wells in WR 460 and 416. Drilling is anticipated to begin in May 2013 and is expected to require approximately 116 days per well.

The lease area is 171 miles (275 km) south

- southwest of the nearest shoreline (Lou isiana),
183 miles (295 km) from the onshore support base at Port Fourchon, Louisiana, and 215 miles (347 km) from the helicopter support base at Amelia , Louisiana ( Figure 1 )

. Water depth s in the lease area range from 2,108 to 2,193 m (6,915 to 7,195 ft). T he drilling rig is yet to be determined but will be a dynamically positioned (DP) drillship

.

This Environmental Impact Analysis ( EIA ) is a project - and site

- specific analysis of COP’ s planned
activities prepared in accordance with the requirements of the Outer Continental Shelf Lands Act (OCSLA), Federal regulations including 30 Code of Federal Regulations ( CFR ) 5 50.2 12 (o ) and
5 50.2 27, and Notice to Lessees and Operators (NTL) 2008

- G04. As specified in NTL 2008

- G04, an EIA focuses on the impacts of a specific plan to the extent feasible. Potential impacts have been analyzed at a broader level in the Programmatic Environmental Impact Statement (EIS) for the Outer Continental Shelf ( OCS ) Oil and Gas Leasing Program (MMS, 2007a)

, in multi

- lease

- sale
E ISs for the Western and Central Gulf of Mexico Planning Areas (MMS, 2007b, 2008) , and in the
E nvironmental Assessment (EA) for Gulf of Mexico deepwater operations and activities (MMS, 2000) . In addition, the Final Supplemental EIS for Central Planning Area lease
sales 216/222 updates environmental information in light of the Macondo ( Deepwater Horizon ) incident and addresses potential impacts of a catastrophic spill (BOEM, 2012). The analyses from these documents are incorporated by reference.

COP submitt ed a revised Gulf of Mexico Regional Oil Spill Response Plan (OSRP) on 4 October 2011 and a Regional OSRP Certification Letter per 30 CFR 254.2(b) to BOEMRE on
1 September 2011. The Certification Letter was accepted by BOEMRE on 8 September 2011.
Worst c ase discharge (WCD) calculations for Garden Banks Block 783, identified as the Regional OSRP WCD, were approved on 29 March 2012 in the DOCD (Control Number N

- 7506) as additional information to the plan per NTL 201 0- N06. The regional OSRP details COP’s plan for response to rapidly and effectively manage oil spills that may result from drilling and production operations. COP has designed its response program based on a regional capability of response to spills ranging from small operational spills to a W CD from a well blowout. COP’s spill

response program meets the response planning requirements of the relevant coastal s tates and applicable F ederal oil spill planning regulations and also includes information regarding COP’s regional oil spill organizatio n and dedicated response assets, potential spill risks, and local
environmental sensitivities. The regional OSRP descri bes personnel and equipment mobilization, the incident management team organization, and an overview of actions and
notifications to be taken in the event of a spill. In addition to the OSR P , ConocoPhillips operations will be governed by the company’s Safety and Environmental Management System (SEMS), a comprehensive system designed to reduce or eliminate the probability of incidents
lead ing to harm to the offshore environment.

1 On 1 October 2011

, the Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE), formerly the

Minerals Management Service (MMS), was replaced by the BOEM and the Bureau of Safety and Environmental Enforcement (BSEE) as part of a major reorganization.Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 2

Figure 1. Vicinity map for the lease area.Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 3 Th is EIA is organized into Sections A through I corresponding to the information required by
NTL 2008

- G04. The main impact

- related discussions are in Section A (Impact

- Producing Factors)
and Section C (Impact Analysis). Table 1 lists and summarizes the BOEM, BSEE, and JOINT NTLs applicable t o this EIA.

Table 1. Notices to Lessees and Operators (NTLs) applicable to this Environmental Impact Analysis ( EIA ).

NTL Title Summary

2012- BSEE

- G01 Marine Trash and Debris
Awareness and Elimination Instructs operators to exercise caution in the handling and disposal of small items and packaging materials

, requires the posting of placards at prominent locations on offshore vessels
and structures

, and mandates a yearly marine trash and debris awareness training and certification process.

2012- JOINT

- G01 Vessel Strike Avoidance and Injured/Dead Protected Species Reporting Recommends protected species identification training,
recommends that vessel operators and crews maintain a vigilant watch for marine mammals and slow down or stop their vessel to avoid striking protected species, and requires operators to report sightings of injured or dead protected species.

2011- JOINT

- G01 Revisions to the List of OCS Blocks Requiring Arch a eological Resource Surveys and Reports Provides new additions to the list of Outer Continental Shelf (OCS) blocks that require archaeological surveys and reports (augments NTL 2005

- G07 )

.

2010- N10 Statement of Compl iance with Applicable Regulations and Evaluation of Information Demonstrating Adequate Spill Response and Well Containment
Resources Informs operators using subsea blowout preventers (BOPs) or surface BOPs on floating facilities that applications for well permits must include a statement signed by an authorized company official stating that the operator will compl y with all applicable regulations, including the increased safety measures regulations (75 FR 63346). Informs operators that BOEMRE will evaluate whether each operator has submitted adequate information demonstrating that it has access to and can deploy containment resources to promptly respond to a blowout or other loss of well control.

2010- N06 Information Requirements for Exploration Plans, Development and Production Plans, and Development Operations Coordination Documents
on the OCS Rescinds the limitations set forth in NTL 2008

- G04 regarding a blowout scenario and worst case discharge scenario, and provides guidance regarding the information required in blowout scenario and worst case discharge scenario descriptions.

2009- G40 Deepwater Benthic Communities Guidance for avoiding and protecting high

- density deepwater benthic communities (including chemosynthetic and deepwater
coral communities ) from damage by OCS oil and gas activities in water depths greater than 300 m (984 ft). Prescribes separation
distances of 610 m (2,000 ft) from each mud and cuttings discharge
location and 76 m (250 ft) from all other seafloor disturbances.

2009- G39 Bi ologically Sensitive Underwater
Features and Areas Guidance for avoiding and protecting biologically sensitive features and areas (i.e., topographic features, pinnacles, low relief live bottom areas, and other potentially sensitive biological features) whe n conducting OCS operations in water depths less than 300 m (984 ft) in the Gulf of Mexico.

2009- G06 Military Warning and Water Test
Areas Provides contact links to command headquarters for military warning and water test areas in the Gulf of Mexico. Lease stipulations require lessees or designated operators to enter into an agreement with the appropriate military command headquarters concerning electromagnetic emissions and the use of boats and aircraft within warning areas or water test areas.Table 1. (Continued).

Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 4 NTL Title Summary

2008- G04 Information Requirements for Exploration Plans and Development Operations Coordination
Documents Provides guidance on the information requi rements for OCS plans, including EIA requirements and information regarding compliance with the provisions of the Endangered Species Act and Marine
Mammal Protection Act.

2005- G07 Archaeological Resource Surveys and Reports Provides guidance on regulations regarding archaeological discoveries, specifies requirements for archaeological resource surveys and reports, and outlines options for protecting archaeological resources.Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 5 

## A. Impac t- Producing Factors

Table 2 is a matrix of impact

- producing factors (IPFs) and potentially affected environmental resources adapted from Form BOEM

- 142. An “X” indicates that an IPF could reasonably be expected to affect a certain resource, and a dash (

-- ) indicates no impact or negligible impact. Where there may be an effect, an analysis is provided in Section C

. Potential IPFs for the proposed activity are listed below and briefly discussed in the following sections.

• Drilling rig presence (including noise
and li ghts)

• Physical disturbance to the seafloor

• Air pollutant emissions

• Effluent discharges • Water intake

• Onshore waste disposal

• Marine debris

• Support vessel and helicopter traffic

• Accidents



## A.1 Drilling Rig Presence (including noise and lights)

The e xploration well s will be drilled using a DP drillship. The drillship will be on site for an
estimated 116 days per well. The physical presence of the drilling rig in the ocean can attract pelagic fishes and other marine life, as discussed in Section C.5.1

.
Drilling operations produce noise that includes strong tonal components at low frequencies and, in some cases, infrasonic frequencies (MMS, 2000). Drilling noise from drillships is not particularly intense and is strongest at low frequencies, averaging 10 to 500 Hz (Richardson

et al., 1995). From a drilling rig , sound and vibration paths to the water flow either through the air or through the risers (MMS, 2000). Drilling rigs also maintain exterior lighting for navigational and aviation safety in accordance with applicable Federal safety regulations.



## A.2 Physical Disturbance to the Seafloor

DP drillships disturb only a very small area of the seafloor around the wellbore where the bottom template and blowout preventer are located. Physical disturbance of the seafloor will be limited to the area where the wellbore penetrates the substrate, where the blowout preventer is placed, and where water

- based drilling mud and cuttings will be discharged at the seafloor during the initial well intervals prior to setting the marine riser. Depending on the specific well configuration, this area is generally about 0.25 ha (0.62 ac) per well

.



## A.3 Air Pollutant Emissions

Air pollutant emissions are calculated in EP Section G

. Offshore air pollutant emissions will result from operations of the drilling rig, as well as service vessels and helicopters. These emissions occur mainly from combustion of fuel by diesel

- powered generators, pumps, or motors and from lighter fuel motors. Primary air pollutants typically associated with OCS activities are suspended particulate matter (PM), sulfur oxides (SO
x ), nitrogen oxides (NO
x ), volatile organic compounds (VOCs), and carbon monoxide (CO). The Air Quality Emissions Report prepared in accordance with BOEM requirements demonstrates that the projected
emissions are below exemption levels specified by 30 CFR 250.303. Therefore, e missions are
not expected to significantly affect the air quality of the onshore area for any of the criteria pollutants. No furthe r analysis or control measures are required.Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 6 Table 2. Matrix of impact

- producing factors and affected environmental resources. X = potential impact; dash (

-- ) = no impact or negligible impact.

Environmental Resources Impact

- producing Factors
Dr illing Rig Presence (incl. noise & lights) Physical Disturbance to Seafloor Air Pollutant Emissions Effluent Discharges Water Intake Onshore Waste Disposal Marine Debris Support Vessel/Helo

Traffic Accidents S mall Fuel Spill Oil Spill (WCD) Physical/Chemical Environment Air quality and greenhouse gases

-- -- X ( 9 )

-- -- -- -- -- X (6) X (6) Water quality

-- -- -- X

-- -- -- -- X (6) X (6) Seafloor Habitats and Biota Soft bottom benthic communities

-- X

-- X

-- -- -- -- -- X (6) High

- density deepwater benthic communities

-- -- (4)

-- -- ( 4)

-- -- -- -- -- X (6) Designated topographic features

-- -- (1)

-- -- ( 1)

-- -- -- -- -- -- Pinnacle trend area live bottoms

-- -- (2)

-- -- (2)

-- -- -- -- -- -- L ive B ottom /Low

- Relief

-- -- (3)

-- -- (3)

-- -- -- -- -- -- Threatened, Endangered, and Protected Species and Critical Habitat Sperm whale (endangered) X (8)

-- -- -- -- -- -- X (8) X (6,8) X (6,8) West Indian manatee (endangered)

-- -- -- -- -- -- -- X (8)

-- X (6,8) Endangered mysticete whale s

-- -- -- -- -- -- -- -- -- -- Non

- endangered marine mammals (protected) X

-- -- -- -- -- -- X X (6) X (6) Sea turtles (endangered/threatened) X (8)

-- -- -- -- -- -- X (8) X (6,8) X (6,8) Piping Plover (threatened)

-- -- -- -- -- - - -- -- -- X (6) Whooping Crane (endangered)

-- -- -- -- -- -- -- -- -- X (6) Gulf sturgeon (threatened)

-- -- -- -- -- -- -- -- -- X (6) Beach mice (endangered)

-- -- -- -- -- -- -- -- -- X (6) Coastal and Marine Birds

Marine birds X

-- -- -- -- -- -- X X (6) X (6) Shorebird s and coastal nesting birds

-- -- -- -- -- -- -- X

-- X (6) Fisheries Resources Pelagic communities and ichthyoplankton X

-- -- X X

-- -- -- X (6) X (6) Essential fish habitat X

-- -- X X

-- -- -- X (6) X (6) Archaeological Resources Shipwreck sites

-- -- (7)

-- -- -- -- -- -- -- X (6) Prehistoric archaeological sites

-- -- (7)

-- -- -- -- -- -- -- X (6) Coastal Habitats and Protected Areas

Beaches

-- -- -- -- -- -- -- X

-- X (6) Wetlands and seagrass beds

-- -- -- -- -- -- -- X

-- X (6) Coastal wildlife refuges and wilderness areas

-- -- -- -- -- -- -- X

-- X (6) Socioeconomic and Other Resources

Recreational and commercial fishing X

-- -- -- -- -- -- -- X (6) X (6) Public health and safety

-- -- -- -- -- -- -- -- -- X (6) Employment and infrastructure

-- -- -- -- -- -- -- -- -- X (6) Recreation and tourism

-- -- -- -- -- -- -- -- -- X (6) Land use

-- -- -- -- -- -- -- -- -- X (6) Other marine uses

-- -- -- -- -- -- -- -- -- X (6)
WCD = worst case discharge.Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 7 Table 2 Footnotes and Applicability:

(1) Activities that may affect a marine sanctuary or topographic feature. Specifically, if the well, rig site, or any anchors will be on the seafloor within the following: (a) 4- mi zone of the Flower Garden Banks, or the 3

- mi zone of Stetson Bank; (b) 1,000

- m, 1

- mi, or 3

- mi zone of any topographic feature (submarine bank) protected by the Topographic

Feature s Stipulation attached to an Outer Continental Shelf (OCS) lease; (c) Essential Fish Habitat (EFH) criteria of 500 ft from any no

- activity zone; or (d) Proximity of any submarine bank (500

- ft buffer zone) with relief greater than 2 m that is not protected by the Topographic Features Stipulation attached to an OCS lease.

• Not applicable. The lease is not within or near a marine sanctuary, topographic feature, or

no

- activity zone. There are no submarine banks in the blocks.
(2) Activities with any bottom disturbance within an OCS lease block protected through the Live Bottom (Pinnacle Trend ) Stipulation attached to an OCS lease.

• The Live Bottom (Pinnacle Trend) Stipulation is not applicable to the lease area.
(3) Activities within any Eastern Gulf OCS block where seafloor habitats are protected by the Live Bottom (Low

- Relief) Stipul ation attached to an OCS lease.

• Activities occur within the Central Gulf OCS, therefore the Live Bottom (Low

- Relief) Stipulation is not applicable to the lease area.
(4) Activities on blocks designated by the BOEM as being in water depths 300 m or greater.

• No impacts on high

- density deepwater benthic communities are anticipated. There are no features indicative of high

- density chemosynthetic communities or coral communities within 6 10 m (2,000 ft) of any drilling mud/cuttings discharge location.
(5) Exploration or production activities where H 2 S concentrations greater than 500 ppm might be encountered.

• EP Section D contains COP ’s request for classification as an area in which H 2 S is absent.
(6) All activities that could result in an accidental spill of produced liquid hydrocarbons or diesel fuel that you determine would impact these environmental resources. If the proposed action is located a sufficient distance from a resource that no impact would occur, the EIA can note that in a sentence or two.

• Accidental hydrocarbon spills could affect the resources marked (X) in the matrix, and impacts are analyzed in Section C

. (7) All activities that involve seafloor disturbances, including ancho r emplacements, in any OCS block designated by the BOEM as having high

- probability for the occurrence of shipwrecks or prehistoric sites, including such blocks that will be affected that are adjacent to the lease block in which your planned activity w ill occur. If the proposed activities are located a sufficient distance from a shipwreck or prehistoric site that no impact would occur, the EIA can note that in a sentence or two.

• No impacts on archaeological resources are expected. The lease area is no t on the list of blocks that have a high potential for historic shipwrecks and is well beyond the 60

- m depth contour used by the BOEM as the seaward extent for prehistoric archaeological site potential in the Gulf of Mexico. An archaeological assessment by Fugro (2012) did not detect any shipwreck remains or other archaeological
resources in the lease area.
(8) All activities that you determine might have an adverse effect on endangered or threatened marine mammals
or sea turtles or their critical habitats

.

• IPFs that may affect marine mammals, sea turtles, or their critical habitats include drilling rig presence, support vessel and helicopter traffic, and accidents. See Section C

. (9) Production activities that involve transportation of produced fluids to shore using shuttle tankers or barges.

• Not applicable.Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 8 

## A.4 Effluent Discharges

Effluent discharges are summarized in EP Section F . All offshore discharges will be in
accordance with requirements of the National Pollutant Discharge Elimination System (N PDES)
General Permit No. GMG 290000 issued by the U.S. Environmental Protection Agency ( USEPA )

. Any d ischarges will be in compliance with the permit terms and monitored as required by the permit.

Water

- based drilling muds and cuttings will be released at the seafloor during the initial well
intervals before the marine riser that allows their return to the surface is set. Excess cement slurry will also be released at the seafloor during casing installation for the riserless portion of the drilling operation s. Synthetic

- based drilling muds (SBMs) will be collected on the rig and either reused by the vendor, or transported to Port Fourchon for recycling and/or disposal at an approved facility. Cuttings wetted with SBMs will be discharged at the seafloor in a ccordance with the NPDES permit.

Other effluent discharges in accordance with the NPDES permit will include non

- contact cooling
water, blowout preventer fluid, treated sanitary and domestic wastes, deck drainage, desalination unit brine, and uncontaminated fresh water and seawater for ballast, bilge and firewater systems

.



## A.5 Water Intake

Seawater will be drawn from the ocean for once

- through, non

- contact cooling of machinery on the drilling rig. Section 316(b) of the Clean Water Act requires NPDES permits to ensure that the location, design, construction, and capacity of cooling water intake structures reflect the best technology available to minimize adverse environmental impact from impingement and entrainment of aquatic organisms. All affected intakes will be in accordance with the design, monitoring, and recordkeeping re quirements of the NPDES permit.



## A.6 Onshore Waste Disposal

Wastes generated during drilling are tabulated in EP Section F

. Approximately 2,276 lb of recyclable and non

- recyclable trash and debris will be generated per day of operations, or a
total of 264,000 lb per well . Th e trash will be transported in storage bins or disposal bags to
Port Fourchon , where it will be picked up by municipal operators for final disposal in accordan ce with applicable regulations.



## A.7 Marine Debris

COP will comply with all regulations relating to solid waste handling and disposal, including the International Convention for the Prevention of Pollution from Ships (MARPOL 73/78) Annex V requirements and USE PA and U.S. Coast Guard ( USCG ) regulations, as well as those of the BSEE

. For example, BSEE regulations at 30 CFR 250.300(a) and (b)(6) prohibit operators from deliberately discharging containers and other similar materials (i.e., trash and debris) into t he marine environment, and 30 CFR 250.300(c) requires durable identification markings on equipment, tools

, and containers (especially drums), and other material. USEPA and USCG regulations require operators to become proactive in avoiding accidental loss of solid waste items by developing waste management plans, posting informational placards, manifesting trash sent to shore, and using special precautions such as covering outside trash bins to preventWalker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 9 accidental loss of solid waste. In addition to the regulations in 30 CFR 250 , BSEE issued
NTL 2012

- BSEE

- G01

, which instructs operators to exercise caution in the handling and disposal of small items and packaging materials, requires the posting of placards at prominent locations
on offshore vessels and struct ures, and mandates a yearly marine trash and debris awareness training and certification process.



## A.8 Support Vessel and Helicopter Traffic

COP’s primary shorebase facility will be located in Port Fourchon, Louisiana. The primary helicopter base will be located in Amelia, Louisiana. N o terminal expansion or construction is planned at the locations.

The project will be supported by one crew boat and two supply vessel s

. It is estimated that the
crew boat will make three round

- trips per week and each supply vessel will make two round

- trips per week. On average, support vessels will make a total of seven round

- trips per week. The boats typically will move to the project area via the most direct route from the
shorebase.

A helicopter will make 10 round

- trip s per week between the drilling rig and the heliport

. The helicopter will be used to transport personnel and small supplies and will normally take the most direct route of travel between the shorebase and the lease area when air traffic and
weather conditi ons permit. Helicopters typically maintain a minimum altitude of 213 m (700 ft) while in transit offshore, 305 m (1,000 ft) over unpopulated areas or across coastlines, and
610 m (2,000 ft) over populated areas and sensitive habitats such as wildlife refu ges and park properties.



## A.9 Accidents

A.9.1 Types of Accidents Evaluated

The analysis in this EIA focuses on two potential accidents:

• A small fuel spill, which is the most likely type of spill during OCS exploration activities; and

• T he WCD for this EP, wh ich is an oil spill resulting from an uncontrolled blowout.

The following subsections summarize assumptions about the size s and fate s of these spills, as
well as COP’s spill response plans. Impacts are analyzed in Section C

.
Three other types of accidents were analyzed in EISs by MMS ( 2007b) and BOEM (2012): chemical spills, vessel collisions, and loss of well control. These types of accidents are discussed briefly in Section A.9.4

.



### A.9.2 Small Fuel Spill

Spill Size . According to the analys e s in MMS (2007b ) and BOEM (2012 ), the most likely type of small spill (<1,000 bbl) as a result of OCS activities is a minor diesel fuel spill. Historically, most diesel spills have been < 1 bbl, and this size is predicted to be the most common in ongoing and future OCS activities in the Western and Central Gulf of Mexico Planning Areas. As the spill size increases, the incident rate declines dramatically (MMS, 2007b ; BOEMRE, 2011; BOEM 2012 ). The average size for spills < 1 bbl is 0.07 bbl, and the median size for spills of 1 to 10 bbl is 3 bbl (MMS, 2007b). For this analysis, a small diesel fuel spill of 3 bbl is assumed. OperationalWalker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 10 experience suggests that the most likely cause of such a spill would be a hose rupture resulting
in the loss of the contents of a f uel transfer hose, which is less than 3 bbl.

Spill Fate

The water

- soluble fractions of diesel are dominated by two - and three

- ringed polycyclic aromatic hyd rocarbons (PAH s ), which are moderately volatile (National Research Council, 2003). The constituents of these oils are light to intermediate in molecular weight and can be readily degraded by aerobic microbial oxidation. D ue to its light density, diesel w ill not sink to the seafloor. Diesel dispersed in the water column can adhere to suspended sediments, but this generally occurs only in coastal areas with high suspended solids loads (National Research Council, 2003) and would not be expected to occur to any appreciable degree in offshore waters of the Gulf of Mexico. Diesel oil is readily and completely degraded by naturally occurring microbes ( National Oceanic and Atmospheric Administration [ NOAA ] , 2006). . The fate of a small fuel spill in the lease area would depend on meteorological and oceanographic conditions at the time, as well as the effectiveness of spill response activities. However, g iven the open ocean location of the lease area and response actions, it is expected
that impacts from a small spill would be minimal (BOEMRE, 2011; BOEM, 2012)

.

For purposes of this EIA, t he fate of a small diesel fuel spill was estimated using NOAA’s Automated Data Inquiry for Oil Spills 2 ( ADIOS2 ) model. This model uses the physical properties of oils in its database to predict the rate of evaporation and dispersion over time, as well as changes in the densi ty, viscosity, and water content of the spilled product. I t is estimated that over 90% of a small diesel spill would be evaporated or dispersed within 24 hours. The area of
the sea surface with diesel fuel on it during this 24

- hour period would range fro m 0.5 to 5 ha (1.2 to 12 ac)

, depending on sea state and weather conditions.

The ADIOS2 results, coupled with spill trajectory information discussed below for a large spill,
indicate that a small fuel spill would not have any impacts on coastal or shorelin e resources. The lease area is 171 miles (275 km) from the nearest shoreline (Louisiana ). Modeling results discussed below indicate that a spill in the lease area would have a 3% or less probability of reaching the coastal areas of Louisiana within 30 da ys after a spill. By that time, essentially 100% of a small fuel spill would have been dispersed or evaporated by natural processes, without taking into account COP’s response measures. MMS (2007b) similarly concluded that spills <1,000 bbl are not expec ted to persist as a slick on the surface of the water beyond a few days and are unlikely to make landfall or reach coastal waters prior to breaking up.
MMS (2007b) noted that this conclusion is supported by a previous analysis of 3- day trajectory model runs, previous weathering analyses, and historical records of spill incidents.

Spill Response

In the unlikely event the shipboard prevention proc edures fail to prevent a fuel spill, response equipment and trained personnel would be activated so that any spill effects would be localized . The drilling rig utilized for these operations will comply with all applicable regulations regarding pollution prevention and control. The rig will have a Shipboard Oil Pollution Emergency Plan (SOPEP), which is reviewed and approved annually by the American Bureau of Shipping. The SOPEP is provided to assist employees in dealing with an unexpected discharge of oil. Its primary purpose is to set in moti on the necessary actions to stop or minimize the discharge of oil and to mitigate its effects. Effective planning ensures that the necessary actions are taken in a structured, logical

, and timely manner.Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 11 and would result only in short

- term environmental consequences

. EP Section H provides a
detailed discussion of CO P’s response to a spill.



### A.9.3 Crude Oil Spill (Worst Case Discharge)

Spill Size

In accordance with requirements of NTL 2010

- N06, COP has estimated an initial WCD flow rate of 75,043 barrels of oil per day (BOPD) for this EP. The estimated maximum tota l time to drill a relief well is 76 days. This estimate includes time to suspend current operations on an existing well, mobilization of another rig, transport of the relief

- drilling rig to the blowout location, and 60 days to drill the relief well and pe rform kill operations. Based on the initial flow rate and the expected time to drill a relief well, the total discharge would be 5,703,268 bbl (initial flow rate x duration). However, incorporating the expected decline in flow rate over the time it takes to drill a relief well, the total discharge would be 3,956,000 bbl. The detailed analysis of this
calculation can be found in EP Section B

. .

St atistics from offshore drilling in the U.S. Gulf of Mexico provide a reasonable basis for evaluating oil spill r isk during exploratory drilling

. Historically, blowouts are rare events and most do not result in oil spills. Holand (1997) estimated a probability of 0.0021 for a deep drilling blowout during exploration drilling based on U.S. Gulf of Mexico data. An u pdated analysis using the SINTEF database estimates a blowout frequency of 0.0017 per exploratory well for non

- North Sea locations (International Association of Oil & Gas Producers, 2010). O f 151 well blowouts in the Gulf of Mexico from 1971 to 1995, only 18 (12%) resulted in oil spills

, with a to tal combined volume of 1,000 bbl of crude oil and condensate released (MMS, 200 0 ). Between 1964 and 1999, almost all offshore spills (94%) from drilling and production

- related operations on the OCS were less than or equal to 1 bbl in size (Anderson and LaBelle, 2000)

. As noted by MMS (2007b), from 1992 to 2005, half of blowouts lasted less than half a day, and fewer than 10% of blowouts resulted in spilled oil. BOEM is in the process of updating t hese spill frequency estimates to include the recent Macondo event; however, significant changes to the spill rates for the entire OCS are not anticipated ( BOEMRE, 2011; BOEM, 2012 ). According to BOEMRE’s Interim Final Drilling Safety Rule ( 75 Federal Reg ister (FR) 63365 dated
10 October 2010 ) issued following the Macondo incident , the baseline risk of a catastrophic blowout is estimated to be about once every 26 years

.

Included in EP Section B are C OP’s calculations and information as required by NTL 2010

- N06,
inc luding descriptions of measures to prevent a blowout, reduce the likelihood of a blowout, and conduct effective and early intervention in the event of a blowout. COP will also comply
with NTL 2010 -N 10 and the Interim Final Drilling Safety Rule, w hich specif ies additional safety
measures for OCS activities.

Spill Trajectory

. The fate of a large oil spill in the lease area would depend on meteorological and oceanographic conditions at the time. The Oil Spill Risk Analysis (OSRA) model is a compute r simulation of oil spill transport that uses realistic data for winds and currents to predict spill fate. The OSRA report by Ji et al. (2004) provides conditional contact probabilities for shoreline segments. The results for Launch Area 47 (where the le ase area is located) are presented in Table 3 . The model predicts no shoreline contacts within 10 days after a spill. After 30 days, four Texas counties and four Louisiana parishes may be contacted, ranging fromWalker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 12 Matagorda County, Texas, to Plaquemines Parish, Louisiana. The greatest probability of
shoreline contact after 30 days is 3% for Cameron Parish, Louisiana.

Table 3. Conditional probabilities of a spill in the lease area contacting shoreline segments (From: Ji et al., 2004). Values are conditional probabilities that a hypothetical spill in the lease area (represented by Oil Spill Risk Analysis Launch Area 47) could contact shoreline segments within 3, 10, or 30 days.

Shoreline Segment County or Parish

, State Conditional Probability of Contact a ( %) 3 Days 10 Days 30 Days
C08 Matagorda County, Texas

-- -- 1
C09 Brazoria County, Texas

-- -- 1
C10 Galveston County, Texas

-- -- 2
C12 Jefferson County, Texas

-- -- 1
C13 Cameron Parish, Louisiana

-- -- 3
C14 Vermilion Parish, Louisiana

-- -- 1
C17 Terrebonne Parish, Louisiana

-- -- 1
C20 Plaquemines Parish, Louisiana

-- -- 1

a Conditional probability refers to the probability of contact within the stated time period, assuming that a spill has occurred (

-- indicates less than 0.5%).

The original OSRA model ing conducted by Ji et al. (2004) did not evaluate the fate of a spill over time periods longer than 30 days, nor d id it predict the fate of a release that continues over a period of wee ks or months, as in the Macondo incident. Also as noted by Ji et al. (2004), the OSRA model does not take into account the chemical composition or biological weathering of oil spills, the spreading and splitting of oil spills, or spill response activities. The model does not assume a particular spill siz e but has generally been used by the BOEM /MMS to evaluate contact probabilities for spills greater than 1,000 bbl.

To provide supplemental information about spill scenarios not addressed in the 30

- day OSRA,

a special OSRA run was conducted to simulate a spill that continues over 90 consecutive days, with each trajectory tracked for 120 days during four seasons for the recent Western and
Central Gulf of Mexico Planning Area Supplemental EIS s ( BOEMRE, 2011; BOEM, 2012). The spatial resolution of this special OSRA run is limited, with five launch points to represent the entire northern Gulf of Mexico. The nearest launch point to the lease area is Launch Point #3,
which is about 71 miles (114 km) to the northeast . For this launch point, potential shoreline

co ntacts after 120 days range from Cameron County, Texas (at the Texas/Mexico border) to Dade County in southeastern Florida. Based on statewide contact probabilities after 120 days, Texas and Louisiana shorelines have the highest likelihood of contact during all four seasons, with Louisiana having higher probabilities in spring (60%) and Texas having higher probabilities during all other seasons (ranging from 41% to 78%). The modeling predicts only a 1% probability of a spill contacting Alabama and Mississ ippi shorelines, and only during spring. The modeling predicts that Florida shorelines could be contacted in any season, with statewide probabilities ranging from 1% to 4%. Based on the 120

- day trajectories, counties, or parishes with greater than 10% co ntact probability during any season range from Matagorda County, Texas, to Plaquemines Parish, Louisiana – the same geographic range predicted using the 30

- day OSRA as
summarized in Table 3

.
Weathering . Following an oil spill, several physical, chemical, and biological processes, collectively called weathering, interact to change the physical and chemical properties of the oil,Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 13 influencing potential effects to marine organisms and ecosystems. The most important weathering processes include spreading, evaporation, dissolution, dispersion into the water column, formation of water

- in

- oil emulsions, photochemical oxidation, microbial degradation, adsorption to suspended particulate matter, and stranding on shore or sedimentation to the seafloor (National Research Council, 2003).

Weathering decreases the concentration of oil and produces changes in its chemical composition, physical properties, and toxicity. The more toxic, light aromatic and aliphatic hydrocarbons are lost rapidly by evaporation and dissolution from a slick on the water surface. Evaporated hydrocarbons are degraded rapidly by sunlight. Biodegradation of oil on the water surface and in the water column by marine bacteria removes first the n

- alkanes and then the light aromatics from the oil. Other petroleum components are biodegraded more slowly.
Photo

- oxidation attacks mainly the medium and high molecular weight PAHs i n the oil on the
water surface.

Spill Response

• procedures to locate and determine the size of a discharge; and . COP submitted a revised Gulf of Mexico Regio nal OSRP to BOEMRE on
4 October 2011. In addition, C OP submitted a Regional OSRP Certification Letter per
30 CFR 254.2 (b) to BOEMRE on 1 September 2011, which was accepted by BOEMRE on
8 September 2011. The OSRP provides a detailed plan for COP to respond to rapidly and effectively manage oil spills that may result from drilling and production operations. The OSRP contains detailed information on “Quick Response” procedures including responsibilities of all COP and contract personnel to report any observed discharge from known or unknown sources;

• contact information for alerting the spill management team complete with names, phone numbers, and locations.

In the event of a WCD, COP has access to surface and subsea response/containment capabilities that could be implemented through various organizations under contract. Clean Gulf Associates (CGA) and Marine Spill Response Corporation (MSRC) are the primary equipment providers for
COP in the Gulf of Mexico region. CGA and MSRC have the ability to rapidly mobilize and deploy substantial spill response resources on a 24

- hour, 7

- days -a- week basis. MSRC and/or their Spill Team Area Responders will operate all CGA equipment. COP also is contracted with National Response Corporation for additional equipment. The Independent Contractor Network of National Response Corporation will provide the closest available personnel and additional equipment as needed.

COP’s OSRP includes subsea well containment capability through their Sponsor Membership in the Marine Well Containment Company (MWCC) LLC. In the event of an incident, MWCC can provide a 15,000

- psi single ram capping stack and dispersant injection capability. MWCC can also install and operate the interim containment system, including subsea flowlines, manifold, and risers. The interim system is engineered for use in depths up to 3,048 m (10,000 ft) and has the capacity to contain 60,000 barrels of liquid per day (BLPD) (and 120 million standard cubic feet per day [MMSCFD] of gas) with potential for expansion.

COP also is contract ed with the Marine Spill Response Corporation (MSRC) for additional spill response equipment. MSRC has a dedicated fleet for the Atlantic/Gulf of Mexico region and additional available equipment staged throughout the U nited States . The equipment MSRC stage s throughout the Gulf of Mexico includes seven oil spill response vessels, two fast responseWalker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 14 vessels, five oil spill response barges, five platform supply ves sels, and 15 shallow

- water barges. Various equipment is outfitted with x

- band and infrared technology.

MSRC recently completed a large expansion of its resources and capability in the Gulf of Mexico, with particular focus on deepwater activities . The expansion is known as “Deep Blue.” Additional MSRC capabilities and a complete equipment listing are available on

- line at: http://www.msrc.org/

.

See EP Section H for a detailed description of COP’s site

- specific r esponse to the WCD for this plan.



### A.9.4 Other Accidents Not Analyzed in Detail

MMS ( 2007b) discusses three other types of accidents: chemical spills, vessel collisions, and loss
of well control. The information from the EIS on these topics remains valid a nd is incorporated by reference into this document. These accidents along with a hydrogen sulfide ( H 2 S) release are discussed briefly below . T here are no other site

- specific issues raised by well drilling proposed in this EP.

Chemical Spills

A study of environmental risks of chemical products used in OCS activities determined that only two chemicals could potentially affect the marine environment in the concentrations typically used: zinc bromide and ammonium chloride (Boehm et al., 2001). The project addressed by this EP does not anticipate t he use of either zinc bromide or ammonium chloride. Most other chemicals are either nontoxic or used in small quantities. No significant impacts are expected from chemical spills. . Chemicals are used in drilling operations to achieve technical goals in the drilling process, improve the efficiency and safety of drilling, and protect associated equipment. Chemicals used during exploration and drilling include surfactants, bentonite clays, olefi ns, inorganic salts, glycols, polymers, barite, and calcium carbonate. In addition to chemicals used in drilling fluids, the following chemicals are likely to be used on the rig: ethylene glycol (blowout prevention control fluid, used in closed cooling loops for crane and main engines and brake coolers), cement (used to cement casing in place), solvents (used in painting operations), hydraulic fluids (used in cranes and other hydraulic rig equipment), lubricating oil and grease (used in reciprocating and electrical equipment), and sodium hypochlorite (dilute, used as laundry bleach and disinfectant). Supplies are renewed on a regular basis by transfer in containers from supply boats (Boehm et al., 2001).

Vessel Collisions

. BOEM data show that from 1996 to 2009 there were 226 O CS

- related
collisions. Most collision mishaps are the result of service vessels colliding with platforms or vessel collisions with pipeline risers. Approximately 10 % of vessel collisions with platforms in
the OCS resulted in diesel spills , and in several collision incidents f ires resulted from hydrocarbon releases. To date, the largest diesel spill associated with a collision occurred in
1979 when an anchor

- handling boat collided with a drilling platform in the Main Pass leasing area, spilling 1,500 bbl. Diesel fuel is the product most frequently spilled

, although oil, natural gas, corrosion inhibitor, hydraulic fluid, and lube oil have also been released as the result of
vessel collision s

. Human error accounts for approximately half of all reported vessel collisions
from 2006 to 2009. As summarized in MMS (2007b ) and BOEM (2012 ), vessel collisions occasionally occur during routine operations. Some of these collisions have caused spills of
diesel fuel or chemicals. COP will comply with all U SCG - and BOEM

- mandated safetyWalker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 15 requirements to minimize the potential for vessel collisions. Impacts are discussed further in recent lease sale EISs ( MMS

, 2007b ; BOEMRE, 2011; and BOEM, 2012).

Loss of Well Control . A loss of well control is the uncontrolled flow of a reservoir fluid that may result in the release of gas, condensate, oil, drilling fluids, sand, or water. Loss of well control is a broad term that includes very minor up to the most serious well control incidents, while
blowouts are considere d to be a subset of more serious incidents with greater risk of oil spill or human injury (MMS, 2007b). Loss of well control may result in the release of synthetic drilling
fluid or loss of oil. COP has a robust system in place to prevent loss of well co ntrol. M easures to prevent a blowout

, reduce the likelihood of a blowout, and conduct effective and early intervention in the event of a blowout are described in EP Section H as required by NTL 2010

- 06

. The potential for a loss

- of

- well

- control event will be minimized by adhering to the requirements of applicable regulations such as the Interim Final Drilling Safety Rule and NTL 2010

- N10 , which specify additional safety measures for OCS activities.

H 2 S Release

. In accordance with Title 30 CFR 250.490(c)

, COP has request ed that W R Blocks 416 and 460 be classified by the BOEM as H 2 S absent. This determination was based on the evaluation of two offset wells (WR 372 Well 1 [ OCS

- G 18701 ] and WR 508 Well 1 [ OCS -G 17001 ]), which pen e trated the stratigraphic section equivalent to the target interval proposed in this EP. Therefore, an H 2 S release is not analyzed further.



## B. Affected Environment

The lease area is in the central Gulf of Mexico, 171 miles ( 275 km ) from the nearest shoreline (Louisiana)

, 183 mil es (295 km) from the onshore support base at Port Fourchon, Louisiana, and 215 miles (347 km) from the helicopter base at Amelia, Louisiana ( Figure 1 ).

Figure 2 shows bathymetric maps of WR 416 and WR 460, including the proposed well surface
locations. Ba sed on the well c learance letters prepared by Gardline Surveys Inc. (Gardline, 2012), the water depth s of the proposed surface locations ran ge from 2,108 to 2,193 m (6,915 to 7,195 ft)

. There is no evidence of significant seafloor or subsurface faulting, fluid expulsion features, or high

- density deepwater benthic communities within a 610

- m (2,000

- ft) radius of the proposed well locations.

A detailed description of the regional affected environment i s provided in recent lease sale EISs

, including meteorolog y, oceanography, geology, air and water quality, benthic communities, threatened and endangered species, biologically sensitive resources, archaeological resources, socioeconomic conditions, and other marine uses (MMS, 2007b, 2008 ; BOEMRE, 2011 ; BOEM,
2012 ). These regional descriptions remain valid and are incorporated by reference. General background information is presented below, and brief descriptions of each potentially affected resource, including site

- specific and/or new information if available , a re presented in Section C

.Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 16 Figure 2. Bathymetric map of Walker Ridge (WR) Blocks 460 and 416 showing the surface locations of proposed wells. (Water depth is in feet.)Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 17 The Macondo spill has resulted in environmental impacts to portions of the Gulf of Mexico. The
lease area is located approximately 218 miles ( 351 km) west

- southwest of the Macondo spill
site. While the Macondo spill resulted in impacts to water quality in the area of the spill, b ased on an analysis of satellite imagery (Environmental Response Management Application [ERMA] Gulf Response, 2012 ), the surface slick did not extend over the lease are a, therefore, existing water quality in the lease area was not likely to have been affected

. In addition to the oil slick

on the sea surface, plumes of submerged oil droplets were produced when subsea dispersants

we re applied at the wellhead (Camilli et al., 2010; Hazen et al., 2010; Joint Analysis Group, 2010a,b,c)

. P rior to the Macondo incident

, water quality in deep, offshore w aters of the Gulf of Mexico was expected to be good

, with low levels of contaminants (Kennicutt, 2000)

. Various monitoring efforts and environmental studies are in progress, but it is not currently possible to precisely estimate the long

- term impacts the spill will have on offshore water quality (BOEMRE, 2011; BOEM, 2012). Based on the information currently available and distance from the Macondo spill site, there is no reason to expect any change in water quality conditions in the
lease area from those predicted prior to and since the Macondo spill in the recent lease s ale EISs (MMS, 2007b, 2008 and BOEMRE, 2011; BOEM, 2012)

.



## C. Impact Analysis

This section analy z es the potential direct and indirect impacts of routine activities and accidents. Impact s have been analyzed extensively in recent lease sale EISs for the Central and Western Gulf of Mexico Planning Areas (MMS, 2007b

, 2008 ; BOEMRE, 2011; BOEM 2012 ) as well as the

E nvironmental Assessment (EA) for Gulf of Mexico deepwater operations and activi ties (MMS, 2000). The information in these documents is incorporated by reference. Potential

s ite

- specific issues are addressed in this section.



## C.1 Physical/Chemical Environment

C.1.1 Air Quality

There are no site

- specific air quality data for the project area. Because of the distance from
shore

- based pollution sources and the lack of sources offshore

, air quality in the lease area is expected to be good. The attainment status of Federal OCS waters is unclassified because there is no provision in the C lean Air Act for classification of areas outside s tate waters (MMS, 2007b)

.
As of March 2012, all Alabama, Florida, and Mississippi coastal counties adjacent to the Central and Western Planning Areas are in attainment of the National Ambient Air Quality St andards (NAAQS) for all criteria pollutants (USEPA, 2012). Two metropolitan areas in Texas are
nonattainment areas for 8

- h ozone (Dallas

- Fort Worth and Houston

- Brazoria) ; and El Paso County, Texas, is a nonattainment area for PM

- 10 (USEPA, 2012).

Winds in the region are driven by the clockwise circulation around the Bermuda High (MMS, 2007b). The Gulf of Mexico is located to the southwest of this center of circulation, resulting in a prevailing southeasterly to southerly flow, which is conducive to transp orting emissions toward shore. However, circulation is also affected by tropical cyclones (hurricanes) during summer and fall, and by extratropical cyclones (cold fronts) during winter.Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 18 BOEM (2012) has reexamined the analysis for air quality presented in previous lease sale EISs (MMS, 2007b, 2008) based on additional information and in consideration of the Macondo oil spill event

. No substantial new information was found that would alter the analysis of potential impact s on air quality

.
Potential IPFs for air quality would be routine air pollutant emissions, a small fuel spill , and a large oil spill (WCD).



### Potential Impacts of Air Pollutant Emissions

Air pollutant emissions are the only routine IPF likely to affect air quality. Offshore air pollutant emissions will result from the drilling rig operations

, helicopters

, and service vessels. These emissions occur mainly from combustion or burning of diesel fuel. The combustion of fuels occurs primarily on diesel

- powered generators, pumps, or motors and from lighter fuel motors. Primary air pollutants typically associated with OCS activities are suspended PM, SO
x , NO x , VOCs, and CO.

Due to the distance from shore, routine operations in the project area are not expected to have any impact o n air quality conditions along the coast, including nonattainment areas. As noted in the lease sale EIS (MMS, 2007b)

, emissions of air pollutants from routine activities in the Central Gulf of Mexico Planning Area are projected to have minimal impacts to onshore air quality because of the prevailing atmospheric conditions, emission heights, emission rates, and the
distance of these emissions from the coastline

. The Air Quality Emissions Report prepared in
accordance with BOEM requirements shows that the projected emissions are below exemption
levels ( EP Section G ). T herefore, according to 30 CFR 250.303

, the emissions will not significantly affect the air quality of the onshore area for any of the criteria pollutants. No further analysis or control measures are required and no significant onshore impacts are expected.

Carbon dioxide (CO 2 ) and methane ( CH 4 ) emissions from the project would constitute a small incremental contribution to greenhouse gas emissions from all OCS activities. According to the Programmatic EIS (MMS, 2007a), estimated CO 2 emissions from all OCS activities in the
2007

- 2012 leasing program are about 0.08% to 0.016% of the global CO 2 emissions from fossil fuel combustion. Greenhouse gas emissions may contribute to climate change, with important effects on temperature, rainfall, frequency of severe weather, ocean acidification, and sea l evel rise (Intergovernmental Panel on Climate Change, 2007). Greenhouse gas emissions from this proposed project represent a negligible contribution to the total greenhouse gas emissions from reasonably foreseeable activities in the Gulf of Mexico area and would not significantly alter any of the climate change impacts evaluated in the lease sale EIS (MMS

, 2007b) or Programmatic EIS (MMS, 2007a).

The Breton Wilderness Area, which is part of the Breton National Wildlife Refuge (NWR), is designated under the Clean Air Act as a Prevention of Significant Deterioration Class I air quality

area. The BOEM is required to notify the National Park Service (NPS) and U.S. Fish and Wildlife Service ( USFWS ) if emissions from proposed projects may affect the Breton Class I area. Additional review and mitigation measures may be required for sources within 186 miles ( 300 km) of the Breton Class I area that exceed emission limits agreed upon by the administering agencies (NPS, 2010). The lease area is approximately 227 miles (366 km) from the Breton Wilderness Area, and therefore significant impacts on the Class I area are not expected.Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 19 

### Potential Impacts of a Small Fuel Spill

Potential impacts o f a small spill on air quality are expected to be consistent with th os e analyzed
and discussed in EISs prepared for recent lease sales (MMS, 2007b, 2008 ; BOEMRE, 2011; BOEM, 2012 ). The probability of a small spill would be minimized by COP’s preventative measures during routine operations, including fuel transfer. In the unlikely event of a spill, implementation of COP’s OSRP will reduce the potential impacts. EP Section H includes a detailed discussion of the spill response measures that would be employed

. Given the open ocean location of the lease area, the extent and duration of air quality impacts from a small spill would not be significant.

A small fuel spill would affect air quality near the spill site by introducing VOCs through evaporation. The ADIOS2 model ( see Section A.9.2 ) indicates that over 90% of a small diesel spill would be evaporated or dispersed within 24 hours. The area of the sea surface with diesel fuel on it would range from 0.5 to 5 ha (1.2 to 12 ac) depending on sea state and weather
conditions.

A small fuel spill would not affect coastal air quality becaus e the spill would not be expected to make landfall or reach coastal waters prior to breaking up (see Section A.9.2 ).



### Potential Impacts of a Large Oil Spill (WCD)

Potential impacts of a large oil spill on air quality are expected to be consistent with th os e analyzed and discussed in recent lease sale EISs (MMS, 2007b, 2008 ; BOEMRE, 2011; BOEM, 2012).

A large oil spill (WCD) could potentially affect air quality by introducing VOCs through evaporation from the slick. The extent and persistence of impacts woul d depend on the meteorological and oceanographic conditions at the time and the effectiveness of spill response

measures. Real

- time wind and current data from the project area would be available at the time of a spill and would be used to assess the fate and effects of VOCs released. Additional air quality impacts could occur if response measures included in situ burning of the floating oil. Burning would generate a plume of black smoke and result in emissions of NO x , SO x , CO, and PM, as well as greenhouse gases. However, in situ burning would occur only after authorization
from the USEPA.

Due to the lease area location (171 miles [275 km]) from the nearest shoreline (Louisiana) , most air quality impacts would occur in offshore waters with minima l chance to affect onshore air quality. Air quality monitoring following the Macondo spill provide s an indication of the potential for air quality impacts from a large spill. The USEPA and the affected states conducted extensive air quality monitoring along the Gulf coast. The air quality monitoring indicated that the levels of ozone and particulates were at levels well below those that would cause short

- term health problems and did not detect any pollutants at levels expected to cause long

- term harm (BO EM, 2012)

.



### C.1.2 Water Quality

There are no site

- specific water quality data for the lease area. Due to the lease location in deep, offshore waters, water quality is expected to be good, with low levels of contaminants.
As noted in a recent lease sale EIS (MMS, 2007b), deepwater areas in the northern Gulf of Mexico are relatively homogeneous with respect to temperature, salinity, and oxygen.Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 20 Kennicutt (2000) noted that the deepwater region has little evidence of contaminants in the dissolved or particula te phases of the water column. However, there are localized occurrences of natural seepage of oil, gas, and brines in near

- surface sediments and up through the water
column.

The lease area is located approximately 218 miles (351 km) from the Macondo spill site . Based on the general circulation pattern seen in the Gulf of Mexico and satellite imagery ( ERMA Gulf Response, 2012 ), the surface slick from that discharge did not extend into this lease area during the spill and water quality within in the lease area was not affected

. W ater quality in deep, offshore waters of the Gulf of Mexico is expected to be good, with low levels of contaminants (Kennicutt, 2000). Based on the information currently available, there is n o reason to expect any change in water quality conditions in the lease area from those predicted in the recent lease s ale EISs (MMS 2007b, 2008; BOEMRE, 2011 ; BOEM, 2012 ).

IPFs potentially affecting water quality are effluent discharges and two types of ac cidents –

a small fuel spill and a large oil spill (WCD).



### Potential Impacts of Effluent Discharges

In general, turbid water can be expected to extend between a few hundred meters and several kilometers down current from the discharge point for water

- based drilling muds and cuttings. SBMs will be collected on the rig and either reused by the vendor, or transported to
Port Fourchon and onwards to an approved facility for recycling and/or disposal in an approved facility. Cuttings wetted with SBMs will be di scharged at the seafloor in accordance with the NPDES permit. All NPDES permit limitations and requirements will be met. There will be no persistent impacts on water quality in the lease area ( National Research Council , 1983; Neff, 1987 ; Neff et al., 200 0 ).

Treated sanitary and domestic wastes , including those from support vessels, may have a slight transient effect on water quality in the immediate vicinity of these discharges. All NPDES permit limitations and requirements and USCG regulations (as applicable) will be met , therefore, l ittle or no impact on water quality is anticipated.

Deck drainage includes all effluents resulting from rain, deck washings, and runoff from curbs, gutters, and drains, including drip pans in wo rk areas. Pollution prevention measures that will be used by COP to meet NPDES permit requirements include the installation of curbs, gutters, drip pans, and drains on deck areas to collect all contaminants and debris. Most deck drains and some of the jo ints at the edge of the rig floor will go overboard or into the moonpool, respectively. A dedicated drip pan will be installed under the rotary table t o prevent ocean discharge from the drains

. The pipe racks, mud pump room, sack store, and drill floor drains go to a holding tank, which is served by a dedicated oily water separator. The well test area, engine room, and other major machinery spaces drains all go to slops tanks, which are served by a large general

- service, oily water separator. The containment devices are temporary and are not meant for permanent storage of waste. On the rare occasion that they contain wastes, they will
be pumped, mopped, or cleaned within a short period of time. The chances of damage to a containment structure during su ch time as it contains wastes are exceedingly small. Based on adherence to COP’s pollution prevention measures, permit limits, and applicable regulations,
l ittle or no impact on water quality is anticipated.Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 21 Other discharges in accordance with the NPDES p ermit, such as desalination unit brine and uncontaminated cooling water, fire water, and ballast water are expected to be diluted rapidly

, resulting in little or no impact on water quality.



### Potential Impacts of a Small Fuel Spill

Potential impacts of a small spill on wate r quality are expected to be consistent with th os e analyzed and discussed in recent EISs (MMS, 2007b, 2008; BOEMRE, 2011; BOEM, 2012 ). The probability of a small spill would be minimized by COP’s preventative measures during routine operat ions

, including fuel transfer. In the unlikely event of a spill, implementation of COP’s
OSRP will help mitigate and reduce the impacts

. EP Section H provides detail on spill response

measures in addition to the summary information provided in this EIA

. Given the open ocean location of the lease area, the extent and duration of water quality impacts from a small spill would not be significant.

A small fuel spill in offshore waters would produce a slick on the water surface and increase the
concentratio ns of petroleum hydrocarbons and their degradation products. The extent and persistence of impacts would depend on the meteorological and oceanographic conditions at the time and the effectiveness of spill response measures. However, it is estimated that over 90% of a small diesel spill would be evaporated or dispersed within 24 hours (see Section A.9.2 ). The area of the sea surface with diesel fuel on it would range from 0.5 to 5 ha (1.2 to 12 ac) depending on sea state and weather conditions.

The water

- soluble fractions of diesel are dominated by two - and three

- ringed PAH s , which are moderately volatile (National Research Council, 2003). The constituents of these oils are light to intermediate in molecular weight and can be readily degraded by aerobic microbial oxidation. Due to its light density, diesel will not sink to the seafloor. Diesel dispersed in the water column can adhere to suspended sediments, but this generally occurs only in coastal areas with high suspended solid loads (National Research Council, 2003) and would not be expected to occur to any appreciable degree in offshore waters of the Gulf of Mexico. Diesel oil is readily and completely degraded by naturally occurring microbes (NOAA, 2006).

A small fuel spill would not affect coastal water quality because the spill would not be expected

to make landfall or reach coastal waters due to both response efforts that would be undertaken
as well as natural attenuation (see Section A.9.2 ).



### Potential I mpacts of a Large Oil Spill (WCD)

Potential impacts of a large oil spill on wate r quality are expected to be consistent with th os e analyzed and discussed in recent lease sale EISs (MMS, 2007b, 2008 ; BOEMRE, 2011; BOEM, 2012 ). A large spill w ould affect wa ter quality by producing a slick on the water surface and increasing the concentrations of petroleum hydrocarbons and their degradation products. The extent and persistence of impacts would depend on the meteorological and oceanographic
conditions at the time and the effectiveness of spill response measures. Most of the oil would be expected to form a slick at the surface, although new information from the Macondo spill indicates that plumes of submerged oil droplets can be produced when subsea dispersant s are applied at the wellhead (Camilli et al., 2010; Hazen et al., 2010; Joint Analysis Group, 2010a,b,c). However, dispersants would be applied only after approval from the USEPA. Small droplets in the water may adhere to suspended sediment and be remov ed from the wate r column (Operational Science Advisory Team Unified Area Command

, 2010).Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 22 Due to the lease area location ( 171 miles [275 km] from the nearest shoreline [Louisiana]), it is expected that most water quality impacts would occur in offshore waters

. Depending on the spill trajectory and the effectiveness of spill response measures, coastal water quality could be
affected. Based on the 30

- day OSRA modeling predictions ( Table 3 ) , nearshore waters and embayments of Cameron Parish, Louisiana, ar e the coastal areas with the most potential for water quality to be affected

.



## C.2 Seafloor Habitats and Biota

Water depths at the proposed well locations range from 2,108 to 2,193 m (6,915 to 7,195 ft). The seafloor at the proposed well locations appears to be smooth and featureless; at WR 460

- A and WR 460 -B it dips to the northeast at approximately 3.4 o , and at WR 416 -D it dips to the southeast at < 1.0 o ( Gardline , 2012). Because no hard bottom areas were detected by side

- scan sonar during the site cleara nce survey, the seafloor is expected to consist mainly of soft bottom
communities. The s urvey did not identify any features that could support high

- density deepwater benthic communities within a 610

- m (2,000

- ft) radius of the three potential well
location s.



### C.2.1 Soft Bottom Benthic Communities

There are no site

- specific benthic community data from the lease area. However, data from the Northern Gulf of Mexico Continental Slope Habitats and Benthic Ecology Study (Wei, 2006;
Rowe and Kennicutt, 2009) can be used to describe typical benthic communities in the area.
Table 4 summarizes data from nearby station s in water depth similar to the lease area. Sediments at these two stations were predominantly clay (55% to 60%) and silt (40% to 55%).

Table 4. Benthic community data from stations near the lease area (Data f r om: Wei, 2006 ; Rowe and Kennicutt, 2009).

Station Water Depth (m) Abundance
Meiofauna (individuals/m 2 ) Macroinfauna (individuals/m 2 ) Megafauna (individuals/ha)

NB5 2,065 117,263 706 1,600

B1 2,255 157,417 1,446 252
Meiofaunal and megafaunal abundances from Rowe and Kennicutt (2009); macroinfaunal data from Wei (2006).

Densities of meiofauna (animals passing through a 0.5

- mm sieve but retained on a 0.062

- mm sieve) in water depths representative of the lease area ( 2,108 to 2,193 m [6,915 to 7,195 ft] ) typically are approximately 200,000 individuals/m 2 (Rowe and Kennicutt, 2009). Nematodes, nauplii, and harpacticoid copepods were the three dominant meiofaunal groups, accounting for about 90% of total abundance.

The benthic macroinfauna is cha racterized by small mean individual sizes and low densities, both of which reflect the meager primary production in Gulf of Mexico surface waters (Wei, 2006). Densities decrease exponentially with water depth. Based on an equation presented by Wei (2006) , macroinfaunal densities in the water depths of the lease area are expected to be about 1,339 to 1,426 individuals/m 2 , or between the macroinfauna densitie s for
the closest locations with similar water depths listed in Table 4

.Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 23 Polychaetes are typically the most abundant macroinfaunal group on the northern Gulf of
Mexico continental slope, followed by amphipods, tanaids, bivalves, and isopods. Wei (2006) recognized four depth

- dependent faunal zones (1 through 4), two of which are divided
ho r izontally. The lease area is in Zone 3 W. Th e most abundant taxa present in this zone, with stations in water depths of 1,875 to 3,008 m ( 6,152 to 9,869 ft) were the polychaetes Levinsenia
uncinata

, Paraonella monilaris

, and Tachyrtrypane sp.

, a bivalve Heterodonata sp. B and an isopod Macrostylis 256

. Megafaunal densities from nearby stations NB5 and B1 were 1,600 and
252 individuals/ha, respectively ( Table 4 ). Common megafauna included motile groups such as decapods, ophiuroids, ho lothurians, and demersal fishes, as well as sessile groups such as sponges and anemones.

Bacteria also are an important component in terms of biomass and cycling of organic carbon (Cruz

- Kaegi, 1998). Bacterial biomass at the depth range of the lease area typically is about

1 to 2 g C/m 2 in the top 15 cm of sediments (Rowe and Kennicutt, 2009).

IPFs potentially affecting soft bottom benthic communities are physical disturbances to the seafloor, effluent discharges (drilling muds and cuttings), and a large oil spill (WCD) from a well blowout at the seafloor. A small fuel spill would not affect benthic communities because the diesel would float and dissipate on the sea surface.



### Potential Impacts of Physical Disturbance to the Seafloor

In water depths such as are encountered in the lease area, DP drillships disturb the seafloor only around the wellbore where the bottom template and blowout preventer are located. Depending upon the specific well configuration, this area is generally about 0.25 ha (0.62 ac) per well

.

T he areal extent of these impacts from a DP rig would be small compared to the lease area itself, and these type soft bottom communities are ubiquitous along the northern Gulf of Mexico continental slope (Gallaway, 1988; Gallaway et al., 2003; Rowe a nd Kennicutt, 2009). Physical disturbance of the seafloor during this project will have no significant impact on soft bottom benthic communities in the region

.



### Potential Impacts of Effluent Discharges

Drilling muds and cuttings are the only effluents that are likely to affect benthic communities. During initial well interval(s) before the marine riser is set, cuttings and seawater

- based “spud mud” will be released at the seafloor. Excess cement slurry will also be released at the seafloor during casing i nstallation for the riserless portion of the drilling operations. Cement slurry components typically include cement mix and some of the same chemicals used in water

- based drilling muds (Boehm et al., 2001). The main impacts will be burial and smothering of benthic organisms within several meters to tens of meters around the wellbore. Soft bottom sediments disturbed by cuttings, drilling muds, and cement slurry will eventually be recolonized through larval settlement and migration from adjacent areas. Be cause some deep

- sea biota grow and reproduce slowly, recovery may require several years.

Discharges of washed SBM cuttings from the rig may affect benthic communities, primarily
within several hundred meters of each wellsite. The fate and effects of SBM cuttings have been reviewed by Neff et al. (2000), and monitoring studies have been conducted in the Gulf of Mexico by Continental Shelf Associates, Inc. (2004, 2006). In general, washed cuttings withWalker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 24 adhering SBMs tend to clump together and form thick cu ttings piles close to the drillsite. Areas of SBM cuttings deposition may develop elevated organic carbon concentrations and anoxic conditions (Continental Shelf Associates, Inc., 2006). Where SBM cuttings accumulate in concentrations of approximately 1, 000 mg/kg or higher, benthic infaunal communities may be adversely affected due to both the toxicity of the base fluid and organic enrichment (with resulting anoxia) (Neff et al., 2000). Infaunal numbers may increase and diversity may decrease as opportun istic species that tolerate low oxygen and high H 2 S predominate (Continental Shelf Associates, Inc., 2006). As the base synthetic fluid is decomposed by microbes, the area will gradually return to pre

- drilling conditions. Disturbed sediments will be

reco lonized through larval settlement and migration from adjacent areas.

T he areal extent of impacts from drilling discharges will be small. Assuming a typical effect
radius of 500 m (1,640 ft), the affected area around a single exploratory wellsite would

rep resent about 3% of the seafloor within a lease block

. Soft bottom communities are ubiquitous along the northern Gulf of Mexico continental slope (Gallaway, 1988; Gallaway et al., 2003; Rowe and Kennicutt, 2009). Impacts from drilling discharges during this project will have no significant impact on soft bottom benthic communities in the region.



### Potential Impacts of a Large Oil Spill (WCD)

The most likely effects of a subsea blowout on benthic communities would be within a few
hundred meters of the wellsit e. The MMS (2007b) estimat ed that a severe subsurface blowout could resuspend and disperse sediments within a 300

- m (984

- ft) radius. While coarse sediments (sands) would probably settle at a rapid rate within 400 m (1,312 ft) from the blowout site, fine sediments (silts and clays) could be resuspended for more than 30 days and dispersed over a much wider area. Based on previous studies, surface sediments at the project area are assumed to largely be silt and clay ( Rowe and Kennicutt, 2009 ).

Recent lease sale EISs (MMS, 2007a, 2008) in dicat ed that oil spills would be unlikely to affect benthic communities beyond the immediate vicinity of the wellhead (i.e., due to physical impacts of a blowout) because the oil would rise quickly to the sea surface directly over the spill location. However, during the Macondo spill, subsurface plumes were reported at a water depth of about 1,100 m (3,600 ft), extending at least 22 miles ( 35 km ) from the wellsite and persisting for more than a month (Camilli et al., 2010). The subsurface plumes apparently resulted from the use of dispersants at the wellhead (Joint Analysis Group, 2010c). While the behavior and impacts of subsurface plumes are not well known, a subsurface plume could
contact the seafloor and affect benthic c ommunities beyond the 300

- m (984

- ft) radius estimated by MMS (2007a, 2008)

, depending on its extent, trajectory, and persistence. This contact could result in smothering and/or toxicity to benthic organisms. The affected area would be recolonized by bent hic organisms over a period of months to years (National Research Council, 2003).



### C.2.2 High

- Density Deepwater Benthic Communities

As defined by NTL 2009

- G40, high

- density deepwater benthic communities are f eatures or areas that could support high

- density chemosynthetic communities, or features or areas that could support high

- density deepwater corals and other associated high

- density hard bottom
communities. Chemosynthetic communities were discovered in the central Gulf of Mexico in
1984 and have been stu died extensively (MacDonald, 2002). Deepwater coral communities are also known from numerous locations in the Gulf of Mexico (Brooke and Schroeder, 2007;Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 25 CSA International, Inc., 2007). These communities occur almost exclusively on authigenic
carbonates created by chemosynthetic communities.

The nearest known high

- density deepwater benthic community is located approximately
41 miles (65 km) north

- northwest of the lease area in GC 852. Three localized fluid escape features with the potential to harbor sen sitive sessile benthic communities were identified
within the Gardline four

- block survey area (WR 416, WR 417, WR 460, and WR 461); the nearest
identified area is located in WR 416/WR 417, approximately 1.8 to 2.8 km (5,977 to 9,034 ft) from the well locations (Gardline, 2012). Based on the well clearance letters by Gardline (2012)
as summarized in EP Section C , t here are no features or areas that could support significant deepwater benthic communities within a 610

- m ( 2,000

- ft ) radius around the proposed wellsites. Therefore, the potential for high

- density deepwater communities near the wellsites is considered low ( Gardline

, 2012).

A large oil spill (WCD) from a well blowout at the seafloor is the only IPF potentially affecting high

- density deepwater benthic communities. A small fuel spill would not affect benthic communities because the diesel fuel would float and dissipate on the sea surface. Because a
DP drillship will be used, there will be no physical disturbance to the seafloor from anchoring during the drilling activities analyzed in this EIA. Monitoring programs on the Gulf of Mexico continental slope have shown that benthic impacts from drilling discharges typically are
concentrated within about 500 m (1,640 ft) of th e wellsite, although detectable deposits may extend beyond this distance (Continental Shelf Associates, Inc., 2004, 2006; Neff et al., 2005). Although small amounts of cuttings particles may reach areas inhabited by high

- density deepwater benthic communit ies, the discharges are not expected to result in significant impacts
to these communities.



### Potential Impacts of a Large Oil Spill (WCD)

Previous analyses (MMS, 2007a, 2008) concluded that oil spills would be unlikely to affect benthic communities beyond t he immediate vicinity of the wellhead (i.e., due to physical impacts of a blowout) because the oil would rise quickly to the sea surface directly over the spill location. However, during the Macondo spill, subsurface plumes were reported at a water depth of about 1,100 m (3,600 ft), extending at least 22 miles ( 35 km ) from the wellsite and persisting for more than a month (Camilli et al., 2010). The subsurface plumes apparently resulted from the use of dispersants at the wellhead (Joint Analysis Group, 20 10c). While the behavior and impacts of subsurface plumes are not well known, a subsurface plume could have the potential to contact high

- density deepwater benthic communities beyond the 300

- m (984

- ft) radius estimated by MMS (2007a, 2008)

, depending on i ts 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, and such approval would be obtained from the USEPA prior to the use of dispersants

.
The biological effects and expected fate of the oil remaining in the Gulf of Mexico from the blowout are still unknown due to the depth and magnitude of this event. Hazen et al. (2010) reported changes in plume hydrocarbon composition with distance from the source . I ncubation experiments with environmental isolates demonstrated faster than expected hydrocarbon biodegradation rates at 5°C. Based on these results, Hazen et al. (2010) suggested the potential exists for intrinsic bioremediation of the oil p lume in the deepwater column without substantial oxygen drawdown.Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 26 Potential impacts of oil on high

- density deepwater benthic communities are discussed in
MMS (2007b). Although chemosynthetic communities live among hydrocarbon seeps, natural seepage is ver y constant and occurs at low rates compared to the potential rates of oil release from a blowout. In addition, seep organisms also require unrestricted access to oxygenated water at the same time as exposure to hydrocarbon energy sources (MacDonald, 2002) . Oil droplets or oiled sediment particles could come into contact with chemosynthetic organisms or deepwater corals. As discussed by MMS (2007b), impacts could include loss of habitat, biodiversity, and live coral coverage; destruction of hard substrate ; change in sediment characteristics; and reduction or loss of one or more commercial and recreational fishery habitats. Sublethal effects could be long

- lasting and affect the resilience of coral colonies to natural disturbances (e.g., elevated water temp erature and diseases).

The potential for a spill to affect deepwater corals is indicated by preliminary findings from a recent (October 2010) survey of deepwater coral habitats near the Macondo spill site (BOEMRE, 2010). Government and academic researchers were working at a site 1,400 m (4,600 ft) deep and approximately 7 miles (11 km) southwest of the Macondo wellhead when they observed dead and dying corals with sloughing tissue and discoloration. Much of the soft coral observed in an area measuring abo ut 15 by 40 m (50 by 130 ft) was covered by what appeared to be a brown flocculent material (BOEMRE, 2010) with signs of widespread stress, including varying degrees of tissue loss and excess mucous production (White et al., 2012). Researchers concluded, based on hopanoid petroleum biomarker analysis of the flocculent material, that it contained oil from the Macondo spill. The injured and dead corals were in an area where a subsea plume of oil had been documented during the spill in June, 2010; corals
els ewhere in the Gulf of Mexico outside the area affected by the plume did not appear to be experiencing higher mortality. The research team concluded that the observed coral injuries likely resulted from exposure to the subsurface oil plume (White et al., 2 012).



### C.2.3 Designated Topographic Features

The block is not within or near a designated topographic feature or a no

- activity zone as identified in NTL 2009

- G39. The nearest designated topographic feature is Ship Shoal South
101 miles (162 km) north of the lease area in Ewing Bank Block 945

.
There are no IPFs associated with either routine operations or accidents that could cause impacts to designated topographic features due to the distance from the lease area. A small fuel spill would float and dissipate on the surface and would not reach these seafloor features.

In the event of an oil spill from a well blowout, a surface slick would not contact these seafloor features. If a subsurface plume were to occur, impacts on these features would be unlikely d ue to the distance and the difference in water depth

. Near

- bottom currents in the region are predicted to flow along the isobaths (Nowlin et al., 2001) and typically would not carry a plume

up onto the continental shelf edge

.



### C.2.4 Pinnacle Trend Area Live Bottoms

The lease area is not covered by the Live Bottom (Pinnacle Trend) Stipulation. As defined by
NTL 2009

- G39, the nearest pinn acle trend area is in Main Pass Block 290, which lies 241 miles ( 387 km) northeast of the lease area.Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 27 There are no IPFs as sociated with either routine operations or accidents that could cause impacts to pinnacle trend area live bottoms due to the distance from the lease area. A small fuel spill would float on the surface and would not reach these seafloor features.

In the ev ent of an oil spill from a well blowout, a surface slick would not contact these seafloor features. If a subsurface plume were to occur, impacts on these features would be unlikely due to the distance and the difference in water depth

. Near

- bottom curren ts in the region are predicted to flow along the isobaths (Nowlin et al., 2001) and typically would not carry a plume

up onto the continental shelf edge

.



### C.2.5 Live Bottom /Low Relief

The lease area is not covered by the Live Bottom (Low

- Relief) Stipulation , which applies to Eastern Gulf of Mexico Planning Area leases in water depths of 100 m (328 ft) or less. The nearest block covered by the live bottom stipulation, as defined by NTL 2009

- G39, is
Destin Dome Block 573, approximately 277 miles ( 446 km) nort heast of the lease area.

There are no IPFs associated with either routine operations or accidents that could cause impacts to live bottom areas due to the distance from the lease area. A small fuel spill would float and dissipate on the surface and would not reach these seafloor features.

In the event of an oil spill from a well blowout, a surface slick would not contact these seafloor features. If a subsurface plume were to occur, impacts on these features would be unlikely due
to the distance and the di fference in water depth

. Near

- bottom currents in the region are predicted to flow along the isobaths (Nowlin et al., 2001) and typically would not carry a plume

up onto the continental shelf

.



## C.3 Threatened, Endangered, and Protected Species and Critical Habitat

This section discusses species listed as endangered or threatened under the Endangered Species Act ( ESA ) . In addition, it includes all marine mammal species in the region, which are protected
under the Marine Mammal Protection Act ( MMPA ).

Endangered or threatened species that may occur in the project area and/or along the northern
Gulf C oast are listed in Table 5 . The table also indicates the location of critical habitat (if designated in the Gulf of Mexico). Critical habitat is defined a s (1) specific areas within the geographical area occupied by the species at the time of listing, if they contain physical or biological features essential to conservation, and those features may require special management considerations or protection; and (2) specific areas outside the geographical area occupied by the species if the agency determines that the area itself is essential for
conservation. The National Marine Fisheries Service ( NMFS ) has jurisdiction for ESA

- listed cetaceans, sea turtles, and fishes in the Gulf of Mexico. The USFWS has jurisdiction for
ESA

- listed birds and the West Indian m anatee.Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 28 Table 5. Federally listed endangered and threatened species potentially occurring in the lease area and along the northern Gulf C oast.

Species Scie ntific Name Status Potential Presence Critical Habitat Designated in Gulf of Mexico Lease Area Coastal

Marine Mammals Sperm whale Physeter macrocephalus E X

-- None West Indian manatee Trichechus manatus latirostris E

-- X Florida (Peninsular) Blue whale Balaenoptera musculus E X a

-- None Fin whale Balaenoptera physalus E X a

-- None Humpback whale Megaptera novaeangliae E X a

-- None North Atlantic right whale Eubalaena glacialis E X a

-- None Sei whale Balaenoptera borealis E X a

-- None
Sea Turtles

Loggerhead turtle Caretta caretta T b X X None Green turtle Chelonia mydas T, E c X X None Leatherback turtle Dermochelys coriacea E X X None Hawksbill turtle Eretmochelys imbricata E X X None Kemp ’ s ridley turtle Lepidochelys kempii E X X None Birds

Piping Plover Charadrius melodus T

-- X Coastal Texas, Louisiana, Mississippi, Alabama, and Florida (Panhandle)

Whooping Crane Grus americana E

-- X Coastal Texas (Aransas National Wildlife Refuge ) Fishes

Gulf sturgeon Acipenser oxyrinchus desotoi T

-- X Coastal Louisiana, Mississippi, Alabama, and Florida (Panhandle) Terrestrial Mammals

Beach mice (A labama, Choctawhatchee, Perdido Key, St. Andrew) Peromyscus polionotus E

-- X Alabama and Florida (Panhandle) beaches

Abbreviations: E = e ndangered; T = t hreatened.

a The blue, fin, humpback, North Atlantic right, and sei whales are rare or extralimital in the Gulf of Mexico and are unlikely to be present in the lease area. b In September 2011 , NMFS and USFWS list ed nine distinct populatio n segments (DPS) of loggerhead turtles under the Endangered Species Act. The Northwest Atlantic Ocean DPS was designated as threatened (76 FR 58868 ).

c The green sea turtle is threatened, except for the Florida breeding population, which is listed as enda ngered.

As mandated by the ESA, BOEM consulted NMFS and the USFWS on possible and potential impacts from the proposed leasing in the Gulf of Mexico on endangered/threatened species and their designated critical habitat (MMS

, 2007a

, b)

. A B iological A ssessment was prepared for each consultation. The formal ESA consultation with NMFS was concluded with receipt of the Biological Opinion on 3 July 2007 (NMFS, 2007). The Biological Opinion concludes that the proposed lease sales and associated activities in the Five

- Year Leasing Plan for Western and Central Planning Areas 2007

- 2012 are not likely to jeopardize the continued existence of threatened and endangered species under NMFS jurisdiction or destroy or adversely modify designated critical habitat. The informal ESA consultation with USFWS was concluded with a
letter dated 14 September 2007. The USFWS concurred with MMS’s determination that proposed actions of the current Five

- Year Leasing Plan were not likely to adversely affect threatened/endangered species or designated critical habitat under USFWS jurisdiction. Following the Macondo spill

, BOEM requested to reinitiat e an ESA consultation with both NMFS
and USFWS on 30 July 2010. At present, the NMFS and US FWS have placed th e consultation

process on hold because they feel the environmental baseline information needs to be updatedWalker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 29 for the post

- Macondo spill environment based on the results of the Natural Resource Damage Assessment ( NRDA ) process. The NRDA data have yet to be released , and the exist ing consultation remain s in effect (BOEM, 2012)

. The existing con sultation recognizes that
BOEM

- required mitigations and other reasonable and prudent measures should reduce the likelihood of impacts from all BOEM

- authorized activities in the Gulf of Mexic o.

Coastal endangered or threatened species that may occur along the northern Gulf Coast include
the West Indian manatee, Piping Plover, Whooping Crane, Gulf sturgeon, and four subspecies of
beach m ouse . Critical habitat has been designated for all of these species as indicated in Table 5 and discussed in individual sections.

Two other coastal species (Bald Eagle and Brown Pelican) are discussed in the MMS (2007b)
lease sale EIS are no longer listed as endangered or threatened . T hese are discussed in
Section C.4.2

, Shorebirds and Coastal Nesting Birds

.
The sperm whale and five species of sea turtles are the only endangered or threatened species likely to occur at or near the lease area. No critical hab itat has been designated for these species in the Gulf of Mexico.

Five endangered mysticete whales (blue whale, fin whale, humpback whale, North Atlantic right whale, and sei whale) also have been reported from the Gulf of Mexico but are considered rare

or extralimital there (Würsig et al., 2000). No critical habitat has been designated for these species in the Gulf of Mexico.

T here are no other endangered plants or animal species in the Gulf of Mexico that are
reasonabl y likely to be effect ed by either ro utine or accidental events associated with this EP.



### C.3.1 Sperm Whale (Endangered)

The only endangered marine mammal likely to be present at or near the project area is the sperm whale ( Physeter macrocephalus )

. Resident populations of s perm whales occur w ithin the Gulf of Mexico; a species description is presented in a recent lease sale EIS (MMS, 2007b). Gulf of Mexico sperm whales are classified as an endangered species and a “strategic stock” (defined as a stock that may have unsustainable human

- caused impacts) by NOAA Fisheries (Waring et al., 2009). No critical habitat for the sperm whale has been designated in the Gulf of
Mexico.

The distribution of sperm whales in the Gulf of Mexico is correlated with mesoscale physical
features such as eddies associated with the Loop Current (Jochens et al., 2008). Sperm whale populations in the north

- central Gulf of Mexico are present there throughout the year (Davis et al., 2000). Results of a multi

- year tracking study show female sperm whales typically

con centrated along the upper continental slope between the 200 - and 1,000

- m (656 - and 3,280

- ft) depth contours ( Jochens et al., 2008 ). Male sperm whales were more variable in their movements and were documented in water depths greater than 3,000 m (9,843 ft)

. Generally, groups of sperm whales sighted in the Gulf of Mexico during the MMS

- funded Sperm Whale Seismic Study (SWSS) consisted of mixed

- sex groups comprising adult females and immatures, and groups of bachelor males. Typical group size for mixed grou ps was 10 individuals (Jochens et al., 2008). SWSS results show that sperm whales transit through the vicinity of the lease area.
Movements of satellite

- tracked individuals suggest that this area of the Gulf continental slope isWalker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 30 within the home range of the Gulf of Mexico population (within the 95% utilization distribution) (Jochens et al., 2008).

IPFs potentially affecting sperm whales include drilling rig presence, noise, and lights; support vessel and helicopter traffic; and two types of accidents – a small fuel spill and a large oil spill (WCD). Effluent discharges are likely to have negligible impacts on sperm whales due to rapid dispersion, the small area of ocean affected, the intermittent nature of the discharges, and the mobility of these marine mammals. Compliance with NTL 2012

- BSEE

- G01 will minimize the potential for marine debris

- related impacts on sperm whales

.

C urrent threats to sperm whale populations worldwide are discussed in a final recovery plan for the sperm whale r ecently published by NOAA (NMFS, 2010 a ). Threats are defined as “any factor that could represent an impediment to recovery

, ” and include fisheries interactions, anthropogenic noise, vessel interactions, contaminants and pollutants, disease, injury from marine debris, research, predation and natural mortality, direct harvest, competition for resources, loss of prey base due to climate change and ecosystem change, and cable laying.
In the Gulf of Mexico , the impacts from many of these threats are identified as either low or
unknown (BOEMRE, 2011; BOEM, 2012)

.



### Potential Impacts of Drilling Rig Presence, Noise, and Lights

Noise from routine drilling activities has the potential to disturb sperm whales. Sperm whales appear to have good mid

- frequency hearing, but the available dat a do not indicate a consistent response to anthropogenic noise ( Southall et al., 2007 ). Noise intensity associated with drilling is relatively weak, and the noise exposure of an individual animal would be transient. There are other OCS facilities and act ivities near the lease area

, and the region as a whole has a large number of similar noise sources. Due to the limited scope and short duration of d rilling activities, this project would represent a small temporary contribution to the overall noise regime

.

NMFS analyzed the potential for impacts of drilling

- related noise on sperm whales in its Biological Opinion for the Gulf of Mexico Oil and Gas Activities: Five

- Year Leasing Plan for Western and Central Planning Areas 2007

- 2012 (NMFS, 2007)

. The analysis noted that semisubmersible drilling rigs emit low sound source levels and concluded that drilling is not expected to produce amplitudes sufficient to cause hearing or behavioral effects in sperm whales; therefore, these effects are insignificant (NMFS, 2007).

Drilling rig lighting and rig presence we re not identified as IPF s for sperm whales in recent lease sale EISs (MMS, 2007b, 2008) or the NMFS (2007) Biological Opinion.



### Potential Impacts of Support Vessel and Helicopter Traffic

Support vessel traffic has the potential to disturb sperm whales

, and there is also a risk of vessel strikes, which are identified as a threat in the recovery plan for this species (NMFS, 2010a ). Data concerning the frequency of vessel strikes are presented in a recent lease sale EIS (MMS, 2007b). To reduce the potential f or vessel strikes, BSEE and BOEM issued
NTL 2012

- JOINT

- G01 , which recommends protected species identification training and that vessel operators and crews maintain a vigilant watch for marine mammals and slow down or stop their vessel to avoid striking pro tected species, and requires operators to report sightings of any injured or dead protected species. When whales are sighted, vessel operators and crewsWalker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 31 are required to attempt to maintain a distance of 91 m (300 ft) or greater whenever possible.
Vessel operators are required to reduce vessel speed to 10 knots or less , when safety permits, when mother/calf pairs, pods, or large assemblages of cetaceans are observed near an underway vessel. Compliance with this NTL will minimize the likelihood of vessel strikes as well as reduce the chance for disturbing sperm whales.

NMFS (2007) analyzed the potential for vessel strikes and harassment of sperm whales . With implementation of the mitigation measures in NTL 2012

- JOINT

- G01 , NMFS concluded that the
likelihood of collisions between vessels and sperm whales would be reduced to insignificant levels. NMFS concluded that the observed avoidance of passing vessels by sperm whales is an advantageous response to avoid a potential threat and is not expected to result in any significant effect on migration, breathing, nursing, breeding, feeding, or sheltering to individuals, or have any consequences at the population level

. With implementation of the vessel strike avoidance measures requirement to maintain a distance of 91 m (300 ft) from sperm whales, the NMFS concluded that the potential for harassment of sperm whales would be reduced to
discountable levels.

Helicopter traffic also has the potential to disturb sperm whales. Smultea et al. (2008) documented responses o f sperm whales offshore Hawaii to fixed wing aircraft flying at an
altitude of 245 m (800 ft). A reaction to the initial pass of the aircraft was observed during
3 (12%) of 24 sightings. All three reactions consisted of a hasty dive and occurred at less than
360 m (1,180 ft) lateral distance from the aircraft. Additional reactions were seen when aircraft
circled certain whales to make further observations. Based on other studies of cetacean responses to sound, the authors concluded that the observed rea ctions to brief overflights by
the aircraft were short

- term and probably of no long

- term biological significance.

W hile flying offshore in the Gulf of Mexico , helicopters maintain altitudes above 213 m (700 ft) during transit to and from the working area. In the event that a whale is seen during transit, the helicopter will not approach or circle the animals. Although responses are possible (Smultea et al., 2008), the NMFS (2007) concluded that this altitude would minimize the potential for disturbing spe rm whales. Therefore, no significant impacts are expected

.



### Potential Impacts of a Small Fuel Spill

Potential spill impacts on marine mammals including sperm whales are discussed in recent lease sale EISs (MMS, 2007b, 2008) and by NMFS (2007) . Oil impacts on marine mammals are discussed by Geraci and St. Aubin (1990). For this EP , there are no unique site

- specific issues with respect to spill impacts on these animals that were not analyzed in the previous
documents

.
The probability of a fuel spill will be minimized by COP’s preventative measures during routine operations including fuel transfer. In the unlikely event of a spill, implementation of COP’s OSRP will mitigate and lessen the potential for impacts on sperm whales. Given the open ocean location of the lease area, the duration of a small spill and opportunity for impacts to occur would be very brief.

A small fuel spill in offshore waters would produce a slick on the water surface and increase the
concentratio ns of petroleum hydrocarbons and their degradation products. The extent and persistence of impacts would depend on the meteorological and oceanographic conditions at the time and the effectiveness of spill response measures. Section A.9.2 discusses the l ikely fateWalker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 32 of a small fuel spill and indicates that over 90% would be evaporated or dispersed naturally
within 24 hours. The area of the sea surface with diesel fuel on it would range from 0.5 to 5 ha (1.2 to 12 ac)

, depending on sea state and weather con ditions.

Direct physical and physiological effects of exposure to diesel fuel could include skin irritation, inflammation, or necrosis; chemical burns of skin, eyes, and mucous membranes; inhalation of toxic fumes; ingestion of oil directly or via contaminated prey; and stress from the activities and noise of response vessels and aircraft (Marine Mammal Commission [ MMC ], 2011 ). However, due to the limited areal extent and short duration of water quality impacts from a small fuel spill, as well as the mobility of sperm whales, no significant impacts would be expected.



### Potential Impacts of a Large Oil Spill (WCD)

Potential spill impacts on marine mammals including sperm whales are discussed in recent EISs (MMS, 2007b, 2008) and by NMFS (2007)

. For this EP , t here are no unique site

- specific issues with respect to spill impacts on these animals.

Impacts of oil spills on sperm whales can include direct impacts from oil exposure, as well as indirect impacts due to response activities and materials (e.g., vessel traffic, no ise, and dispersants) (MMC, 2011 ). Direct physical and physiological effects can include skin irritation, inflammation, or necrosis; chemical burns of skin, eyes, and mucous membranes; inhalation of toxic fumes; ingestion of oil (and dispersants ) directly or via contaminated prey; and stress from the activities and noise of response vessels and aircraft. Complications of the above may lead to dysfunction of immune and reproductive systems, physiological stress, declining physical condition, and death. Behavioral responses can include displacement of animals from prime
habitat

, disruption of social structure

, changing prey availability and foraging distribution and/or
patterns
, changing reproductive behavior/productivity, and changing movement pa tterns or migration (MMC, 2011 ).

In the event of a large spill, the level of vessel and aircraft activity associated with spill response could disturb sperm whales and potentially result in vessel strikes, entanglement, or other injury or stress. Response vessels would operate in accordance with NTL 2012

- JOINT

- G01 to reduce the potential for striking or disturbing these animals.



### C.3.2 West Indian Manatee (Endangered)

M ost of the Gulf of Mexico manatee population is located in peninsular Florida (USFWS, 2001). Manatee sightings in Louisiana have increased as the species extends its presence farther west of Florida in the warmer months (Wilson, 2003). A species description is presented in a recent lease sale EIS (MMS, 2007b) and in the recovery plan for this species (USFWS, 2001).

IPFs potentially affecting manatees include support vessel and helicopter traffic and a large oil spill (WCD). A small fuel spill in the lease area would be unlikely to affect manatees because the lease area is approximately 171 miles (275 km) from the nearest shoreline (Louisiana) . As explained in Section A.9.2 , a small fuel spill would not be expected to make landfall or reach coastal waters prior to breaking up

. Compliance with NTL 2012

- BSEE

- G01 will minimize the potential for marine debris

- related impacts on manatees.Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 33 

### Potential Impacts of Support Vessel and Helicopter Traffic

Support vessel traffic has the potential to disturb manatees

, and there is also a risk of vessel strikes, wh ich are identified as a threat in the recovery plan for this species (USFWS, 2001).
To reduce the potential for vessel strikes, BSEE and BOEM issued NTL 2012

- JOINT

- G01 , which recommends protected species identification training and that vessel operators a nd crews maintain a vigilant watch for marine mammals and slow down or stop their vessel to avoid striking protected species

, and requires operators to report sightings of any injured or dead protected species. Compliance with NTL 2012

- JOINT -G01 will minimize the likelihood of vessel strikes, and no significant impacts on manatees are expected.

Helicopter traffic also has the potential to disturb manatees. Rathbun (1988) reported that manatees were disturbed more by helicopters than by fixed

- wing aircraft ; however, the helicopter was flown at relatively low altitude s of 20 to 160 m (66 to 525 ft). Helicopters used in support operations maintain a minimum altitude of 213 m (700 ft) while in transit offshore,
305 m (1,000 ft) over unpopulated areas or acros s coastlines, and 610 m (2,000 ft) over populated areas and sensitive habitats such as wildlife refuges and park properties. This mitigation measure will minimize the potential for disturbing manatees, and no significant impacts are expected.



### Potential Im pacts of a Large Oil Spill (WCD)

In the event that manatees were exposed to oil, effects could include direct impacts from oil exposure, as well as indirect impacts due to response activities and materials (e.g., vessel traffic, noise, and dispersants ) (MM C, 2011 ). Direct physical and physiological effects can include skin irritation, inflammation, or necrosis; chemical burns of skin, eyes, and mucous membranes; inhalation of toxic fumes; ingestion of oil (and dispersants) directly or via contaminated prey (or contaminated vegetation, in the case of manatees); and stress from the activities and noise of response vessels and aircraft. Complications of the above may lead to dysfunction of immune and reproductive systems, physiological stress, declining physi cal condition, and death. Behavioral responses can include displacement of animals from prime habitat

, disruption of
social structure

, changes to foraging distribution and/or patterns

, changing reproductive behavior/productivity, and changing movement pat terns or migration (MMC, 2011 ).

In the event that a large spill reached coastal waters where manatees were present , the level of vessel and aircraft activity associated with spill response could disturb manatees and potentially result in vessel strikes, entanglement, or other injury or stress. Response vessels would operate
in accordance with NTL 2012

- JOINT

- G01 to reduce the potential for striking or disturbing these
animals , and therefore no significant impacts are expected

.



### C.3.3 Endangered Mysticete Whales

Five endangered mysticete whales (blue whale, fin whale, humpback whale, North Atlantic right whale, and sei whale) also have been reported from the Gulf of Mexico but are considered rare or extralimital there (Würsig et al., 2000). No critical habitat has been designated for these species in the Gulf of Mexico.

Due to the rare occurrence of these whales in the Gulf of Mexico and the limited sco pe and duration of the project, it is highly unlikely that any endangered mysticete would come into

contac t with any project activities, either routine operations or accidents . NMFS did not includeWalker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 34 any of these mysticete whales as affected species in its Biological Opinion (NMFS, 2007)

. Potential impacts are analyzed in recent lease sale EISs (MMS, 2007b, 20 08)

, and those analyses are incorporated by reference. If any of these whales were present in the area, potential impacts would be the same as those discussed below in Section C.3.4

.



### C.3.4 Non

- Endangered Marine Mammals (Protected)

Excluding the seven enda ngered species that have been cited previously, there are 22 additional species of marine mammals that may be found in the Gulf of Mexico. This includes 2 mysticete whales, the dwarf and pygmy sperm whales, 4 species of beaked whales, and 1 4 species of delphinids . All marine mammals are protected species under the MMPA. The most common

non

- endangered cetaceans in the deepwater environment are odontocetes such as the pantropical spotted dolphin, spinner dolphin, and C lymene dolphin. A brief summary is

pr esented below, and a dditional information on these groups is presented in a recent lease sale EIS (MMS, 2007b).

Mysticete whale s . Two species of non

- endangered mysticete whales are known from the Gulf
of Mexico. The Bryde’s whale ( Balaenoptera edeni ) has been sighted most frequently along the
100

- m (328

- ft) isobath (Davis and Fargion, 1996; Davis et al., 2000). Most sightings have been made in the DeSoto Canyon region and off western Florida, although there have been some in
the west

- central portion of t he northeastern Gulf. The minke whale ( Balaenoptera

acutorostrata ) is considered rare in the Gulf of Mexico, with the only confirmed records coming from strandings (Würsig et al., 2000). Based on the available data, it is possible that Bryde’s
whales could occur in the lease area.

Dwarf and pygmy sperm whales

. At sea, it is difficult to differentiate dwarf sperm whales ( Kogia sima ) from pygmy sperm whales ( Kogia breviceps ), and sightings are often grouped together as Kogia spp. Both species have a worldwide distribution in temperate to tropical waters. In the Gulf of Mexico, both species occur primarily along the continental shelf edge and in deeper waters off the continental shelf (Mullin et al., 1991). Either species could occur in the
lease are a.

Beaked whales . Four species of beaked whales are known from the Gulf of Mexico. They are Blainville’s beaked whale ( Mesoplodon densirostris ), Cuvier’s beaked whale ( Ziphius cavirostris ), Sowerby’s beaked whale ( Mesoplodon bidens ), and Gervais’ beaked whale ( Mesoplodon

europaeus ). Stranding records in the Gulf of Mexico suggest that Gervais’ beaked whale is the most common and Sowerby’s is extralimital. Due to the difficulties of at

- sea identification,
beaked whales in the Gulf of Mexico are identifie d either as Cuvier’s beaked whales or are grouped into an undifferentiated complex ( Mesoplodon spp. and Ziphius spp.). In the northern Gulf of Mexico, they are broadly distributed in water depths greater than 1,000 m (3,281 ft) over lower slope and abyssal landscapes (Davis et al., 2000). Any of these species could occur in the
lease area.

D elphinids . Fourteen species of delphinids are known from the Gulf of Mexico, including Atlantic spotted dolphin ( Stenella frontalis ), bottlenose dolphin ( Tursiops tru ncatus ), Clymene dolphin ( Stenella clymene ), f alse killer whale ( Pseudorca crassidens )

, Fraser’s dolphin ( Lagenodelphis hosei ) , k iller whale ( Orcinus orca ) , m elon

- headed whale ( Peponocephala electra )

, p antropical spotted dolphin ( Stenella attenuata )

, p ygmy killer whale ( Feresa attenuata )

, short

- finned pilot whale ( Globicephala macrorhynchus ) , R isso’s dolphin ( Grampus griseus )

,Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 35 r ough

- toothed dolphin ( Steno bredanensis ) , s pinner dolphin ( Stenella longirostris ) , and s triped dolphin ( Stenella coeruleoalba ). An y of these species could occur in the lease area. The most

common non

- endangered cetaceans in the deepwater environment are the pantropical spotted dolphin, spinner dolphin, and C lymene dolphin.

IPFs potentially affecting non

- endangered marine mammals include drilling rig presence, noise, and lights; support vessel and helicopter traffic; and two types of accidents – a small fuel spill and a large oil spill ( WCD ) . Effluent discharges are likely to have negligible impacts on marine mammals due to rapid dis persion, the small area of ocean affected, the intermittent nature of the discharges, and the mobility of marine mammals. Compliance with NTL 2012

- BSEE

- G01 will minimize the potential for marine debris

- related impacts on marine mammals.



### Potential Impacts of Drilling Rig Presence, Noise, and Lights

Noise from routine drilling activities has the potential to disturb marine mammals. Most odontocetes (toothed whales and dolphins) use higher frequency sounds than th ose produced by OCS drilling activities (Richardson et al., 1995). Noise intensity associated with drilling is relatively weak, and the noise exposure of an individual animal would be transient. There are other OCS facilities and activities near the lease area

, and the region as a whole has a large number of similar sources. Due to the limited scope and short duration of drilling activities , this project would represent a small temporary contribution to the overall noise regime

, and any
short

- term impacts are not expected to be biologically signifi cant to marine mammal populations.

Drilling rig lighting and rig presence are not identified as IPF s for marine mammals in recent lease sale EISs (MMS, 2007b, 2008).



### Potential Impacts of Support Vessel and Helicopter Traffic

Support vessel traffic has the potential to disturb marine mammals

, and there is also a risk of
vessel strikes. Data concerning the frequency of vessel strikes are presented in a recent lease sale EIS (MMS, 2007b). To reduce the potential for vessel strikes, BSEE and BOEM issued
NTL 2 012

- JOINT

- G01 , which recommends protected species identification training and that vessel operators and crews maintain a vigilant watch for marine mammals and slow down or stop their vessel to avoid striking protected species, and requires operators to rep ort sightings of any injured or dead protected species. Vessel operators and crews are required to attempt to
maintain a distance of 91 m (300 ft) or greater when whales are sighted and 45 m (150 ft) when small cetaceans are sighted. When cetaceans are s ighted while a vessel is underway, vessels must attempt to remain parallel to the animal’s course and avoid excessive speed or abrupt changes in direction until the cetacean has left the area. Vessel operators are required to reduce vessel speed to 10 kno ts or less when mother/calf pairs, pods, or large assemblages of cetaceans are observed near an underway vessel

, when safety permits. Compliance with
NTL 2012

- JOINT

- G01 will minimize the likelihood of vessel strikes as well as reduce the chance
for distur bing marine mammals and therefore no significant impacts are expected

.

Aircraft traffic also has the potential to disturb marine mammals (W ü rsig et al., 1998). However, while flying offshore, helicopters maintain altitudes above 213 m (700 ft) during tran sit to and from the working area. This altitude will minimize the potential for disturbing marine mammals

, and no significant impacts are expected ( MMS, 2007b ).Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 36 

### Potential Impacts of a Small Fuel Spill

Potential spill impacts on marine mammals are discusse d in recent EISs (MMS, 2007b, 2008)

, and oil impacts on marine mammals in general are discussed by Geraci and St. Aubin (1990). For
this EP , there are no unique site

- specific issues with respect to spill impacts on these animals.

The probability of a fuel spill will be minimized by COP’s preventative measures during fuel transfer. In the unlikely event of a spill, implementation of COP’s OSRP is expected to lessen the potential for impacts on marine mammals

. EP Section H provides detail on spill response

measures , along with a summary of those measures in this EIA

. Given the open ocean location of the lease area, the limited duration of a small spill and response efforts, it is expected that any impacts would be brief and minimal

.
A small fuel spill in offshore waters would produce a slick on the water surface and increase the concentrations of petroleum hydrocarbons and their degradation products. The extent and persistence of impacts would depend on the meteorological and ocean ographic conditions at the time and the effectiveness of spill response measures. Section A.9.2 discusses the likely fate of a small fuel spill and indicates that over 90% would be evaporated or dispersed naturally
within 24 hours. The area of the sea su rface with diesel fuel on it would range from 0.5 to 5 ha (1.2 to 12 ac)

, depending on sea state and weather conditions.

Direct physical and physiological effects of exposure to diesel fuel could include skin irritation, inflammation, or necrosis; chemical burns of skin, eyes, and mucous membranes; inhalation of toxic fumes; ingestion of oil directly or via contaminated prey; and stress from the activities and noise of response vessels and aircraft (MMC, 2011 ). However, due to the limited areal extent
and short duration of water quality impacts from a small fuel spill, as well as the mobility of marine mammals, no significant impacts would be expected.



### Potential Impacts of a Large Oil Spill (WCD)

Potential spill impacts on marine mammals are discussed in re cent EISs (MMS, 2000, 2007b

, 2008 ; BOEMRE, 2011; BOEM, 2012 )

. For this EP , there are no unique site

- specific issues

. Impacts of oil spills on marine mammals can include direct impacts from oil exposure, as well as indirect impacts due to response activit ies and materials (e.g., vessel traffic, no ise, and dispersants) (MMC, 2011 ). Direct physical and physiological effects can include skin irritation, inflammation, or necrosis; chemical burns of skin, eyes, and mucous membranes; inhalation of toxic fumes; ingestion of oil (and dispersants) directly or via contaminated prey (or contaminated vegetation, in the case of manatees); and stress from the activities and noise of response vessels and aircraft. Complications of the above may lead to dysfunction of im mune and reproductive systems, physiological stress, declining physical condition, and death. Behavioral responses can include displacement of animals from prime habitat

, disruption of
social structure

, changing prey availability and foraging distribution and/or patterns

, changing reproductive behavior/productivity, and changing movement patterns or migration (MMC, 201 1 ).

In the event of a large spill, the level of vessel and aircraft activity associated with spill response
could disturb marine mammals and potentially result in vessel strikes, entanglement, or other injury or stress. Response vessels would operate in accordance with NTL 2012

- JOINT -G01 to reduce the potential for striking or disturbing these animals , and therefore no significant impacts are expected

.Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 37 Data from the Macondo spill indicate that numerous marine mammals could be affected by a large spill. According to NMFS (2011a), through April 2011, 157 dead marine mammals were reported, of which most were bottlenose dolphins. Other affected species included dwarf/pygmy sperm whale, melon

- headed whales, and spinner dolphins. Because of known low detection rates of carcasses, it is possible that the number of marine mammal deaths is significantly underestimated (Williams et al., 2011). Also, necropsies to confirm the cause of death could not be conducted for many of these marine mammals, and it is possible that some were not related to the Macondo spill.



### C.3. 5 Sea Turtles (Endangered/Threatened)

F ive species of endangered or threatened sea tur tles may be found near the lease area. L eatherback ( Dermochelys coriacea ), Kemp's ridley ( Lepidochelys kempii ), and hawksbill ( Eretmochelys imbricata ) turtles are endangered . The Northwest Atlantic Ocean distinct population segment of the loggerhead turtle ( Caretta caretta ) is classified as threatened (76 FR 58868) . The green turtle ( Chelonia mydas ) is listed as threatened, except for the Florida
and Pacific Coast of Mexico breeding population s , which are listed as endangered. Species descriptions are presented in MMS ( 2007b).

The extent and scope of the Macondo spill represents new information not assessed in the existing ESA Section 7 consultation under the current Five

- Year Program. As a result of this new information, BOEM reinitiated ESA Sectio n 7 consultation on the existing Gulf of Mexico lease
sale EIS with NMFS and the US FWS on 30 July 2010. However, NMFS and the USFWS have placed the consultation process on hold pending the results of the NRDA post

- Macondo spill data review, which has yet to be released. The existing consultation currently remain s in effect (BOEM, 2012)

.

BOEM RE (2011) and BOEM (2012) reexamined the impacts analys es presented in MMS (2007b, 2008) for the five sea turtle species that inhabit the Gulf of Mexico based on addit ional information and in consideration of the Macondo spill. No new information was found that would alter the potential impact s on sea turtles described in previous EISs . In most foreseeable cases, exposure to hydrocarbons persisting in the sea following the dispersal of an oil slick will result in sublethal impacts (e.g., decreased health, reproductive fitness, and longevity; and increased vulnerability to disease) to sea turtles.

Leatherbacks and loggerheads are the most likely species to be pr esent near the lease area as adults. Green, hawksbill, and Kemp’s ridley turtles are typically inner shelf and near shore species, unlikely to occur near the lease area as adults. Hatchlings or juveniles of any of the sea
turtle species may be present in deepwater areas, including the lease area, where they may be
associated with Sargassum and other flotsam.

Sea turtle nesting in the northern Gulf of Mexico can be summarized by species as follows:

• Loggerhead turtles – Loggerheads nest in significant number s along the Florida Panhandle (Florida Fish and Wildlife Conservation Commission, 2012a) and, to a lesser extent, from Texas through Alabama (NMFS and USFWS, 2008) . The nearest significant nesting area of loggerhead turtles is found in Louisiana, on beach es within the Breton NWR ;

• Green and leatherback turtles – Green and leatherback turtles infrequently nest on Florida Panhandle beaches (Florida Fish and Wildlife Conservation Commission, 2012b,c );Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 38 • Kemp’s ridley turtles – The main Kemp’s ridley nesting site is Rancho Nuevo beach, Tamaulipas, Mexico (NMFS et al., 2011). Kemp’s ridley turtles typically do not nest anywhere near the project area, although there have been occasional reports of Kemp’s ridleys nesting in Alabama (Share the Beach, 201 2 ); and

• Hawks bill turtles – Hawksbills typically do not nest anywhere near the project area (USFWS, 2011a)

.
IPFs potentially affecting sea turtles include drilling rig presence, noise, and lights; support vessel and helicopter traffic; and two types of accidents – a sm all fuel spill and a large oil spill ( WCD ) . Effluent discharges are likely to have negligible impacts on sea turtles due to rapid dispersion, the small area of ocean affected, and the intermittent nature of the discharges. Compliance with NTL 2012

- BSEE

- G01 will minimize the potential for marine debris

- related impacts on sea turtles.



### Potential Impacts of Drilling Rig Presence, Noise, and Lights

Offshore drilling activities produce a broad array of sounds at frequencies and intensities that may b e detected by sea turtles (Geraci and St. Aubin, 1987). Potential impacts may include behavioral disruption and temporary or permanent displacement from the area near the sound source. Certain sea turtles, especially loggerheads, may be attracted to offs hore structures (Lohoefener et al., 1990) and, thus, may be more susceptible to impacts from sounds produced during routine operations. Helicopters and service vessels may also affect sea turtles due to machinery noise and/or visual disturbances. The mos t likely impacts would be short

- term behavioral changes such as diving and evasive swimming, disruption of activities, or departure from the area. Due to the limited scope and short duration of drilling activities , these
short

- term impacts are not expecte d to be biologically significant to sea turtle populations.

Artificial lighting can disrupt the nocturnal orientation of sea t urtle hatchlings (Witherington, 1997; Tuxbury and Salmon, 2005). However, hatchlings may rely less on light cues when they are offshore than when they are emerging on the beach (Salmon and Wyneken, 1990). The NMFS (2007) concluded that the effects of lighting from offshore structures on sea turtles are insignificant.



### Potential Impacts of Support Vessel and Helicopter Traffic

Support vessel traffic has the potential to disturb sea turtles

, and there is also a risk of vessel
strikes. Data show that vessel traffic is one cause of sea turtle mortality in the Gulf of Mexico (Lutcavage et al., 1997). While adult sea turtles are visible at the surface during the day and in clear weather, they can be difficult to spot from a moving vessel when resting below the water surface, during nighttime, or during periods of inclement weather. To reduce the potential for vessel strikes, BSEE a nd BOEM issued NTL 2012

- JOINT -G01 , which recommends protected species identification training and that vessel operators and crews maintain a vigilant watch for sea turtles and slow down or stop their vessel to avoid striking protected species, and requires operators to report sightings of any injured or dead protected species. When sea turtles are sighted, vessel operators and crews are required to attempt to maintain a distance of 45 m (150 ft) or greater whenever possible. Compliance with this NTL will minimize the likelihood of vessel strikes as well as reduce the chance for disturbing sea turtles (NMFS, 2007).

Helicopter traffic also has the potential to disturb sea turtles. However, while flying offshore, helicopters maintain altitudes above 213 m (7 00 ft) during transit to and from the working area.Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 39 This altitude will minimize the potential for disturbing sea turtles, and no significant impacts are expected.



### Potential Impacts of a Small Fuel Spill

Potential spill impacts on sea turtles are discussed in recent EISs (MMS, 2007b, 2008) and the
NMFS Biological Opinion (NMFS, 2007)

. For this EP , there are no unique site

- specific issues with respect to spill impacts on these animals.

The probability of a fuel spill will be minimized by COP’s preventative measures during fuel transfer. In the unlikely event of a spill, implementation of COP’s OSRP is expected to minimize potential impacts on sea turtles

. EP Section H provides detail on spill response measures. Given the open ocean location of the lease area, the duration of a small spill and opportunity for impacts to occur would be very brief.

A small fuel spill in offshore waters would produce a slick on the water surface and increase the concentrations of petroleum hydrocarbons and their degradation products. The extent and persistence of impacts would depend on the meteorological and oceanographic conditions at the time and the effectiveness of spill response measures. Section A.9.2 discusses the likely fate of a small fuel spill and indicates that over 90% would be evaporated or dispersed naturally
within 24 hours. The area of the sea surface with diesel fuel on it would range from 0.5 to 5 ha (1.2 to 12 ac)

, depending on sea state and weather conditions.

Direct physical and physiological effects of exposure to diesel fuel could include skin irritation, inflammation, or necrosis; chemical burns of skin, eyes, and mucous membranes; inhalation of toxic fumes; ingestion of oil directly or via contaminated prey; and stress from the activities and
noise of response vessels and aircraft. However, due to the limited areal extent and short duration of water quality impacts from a small fuel spill, no significant impacts would be expected.

A small fuel spill in the lease area would be unlikely to affect sea turtle nesting beaches, as the
lease area is 171 miles ( 275 km) from the nearest shoreline (Louisiana) . As explained in
Section A.9.2 , a small fuel spill would not be expected to make landfall or reach coastal waters prior to breaking up

.



### Potential Impact s of a Large Oil Spill (WCD)

Impacts of oil spills on sea turtles can include direct impacts from oil exposure, as well as indirect impacts due to response activities and materials (e.g., vessel traffic, noise, and dispersants). Direct physical and physio logical effects can include skin irritation, inflammation, or necrosis; chemical burns of skin, eyes, and mucous membranes; inhalation of toxic fumes and smoke (e.g., from in situ burning of oil) ; ingestion of oil (and dispersants) directly or via
contamin ated food; and stress from the activities and noise of response vessels and aircraft. Complications of the above may lead to dysfunction of immune and reproductive systems, physiological stress, declining physical condition, and death. Behavioral respons es can include displacement of animals from prime habitat

, disruption of social structure

, changing food availability and foraging distribution and/or patterns

, changing reproductive behavior/productivity, and changing movement patterns or migration. In t he unlikely event of a spill, implementation of COP’s OSRP is expected to minimize the potential for these types of impacts on sea turtles

. EP Section H provide s detail on spill response measures.Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 40 Studies of oil effects on loggerheads in a controlled setting (Lutcavage et al., 1995) suggest that sea turtles show no avoidance behavior when they encounter an oil slick

, and any sea turtle in an affected area would be expected to be exposed. Sea turtles’ diving behaviors also put them at risk. Sea turtles rapidly inhale a large volume of air before diving and continually resurface
over time , which may result in repeated exposure to volatile vapors and oiling (NMFS, 2007).

The OSRA results summarized in Table 3 predict that Texas and Louisiana shorelines t hat support limited sea turtle nesting could be contacted within 30 days. The nearest nesting area of loggerhead turtles is found in St. Bernard Parish, Louisiana, on beaches within the Breton
NWR. This area i s not expected to be contacted within 30 days

. The 120

- day OSRA modeling estimates no contacts with Alabama and Florida Panhandle shorelines that support significant loggerhead sea turtle nesting within 30 days and a maximum contact probability of 1% for these

areas within 120 days (BOEM, 2012)

.
Spi lled oil reaching sea turtle nesting beaches could have e ffects on nesting sea turtles and egg development (NMFS, 2007). An oiled beach could affect nest site selection or result in no nesting at all (e.g., false crawls). Upon hatching and successfully reaching the water, hatchlings are subject to the same types of oil spill exposure hazards as adults. Hatchlings that contact oil residues while crossing a beach can exhibit a range of effects, from acute toxicity to impaired movement and normal bodily fun ctions (NMFS, 2007).

In the event of a large spill, the level of vessel and aircraft activity associated with spill response could disturb sea turtles and potentially result in vessel strikes, entanglement, or other injury or stress. Response vessels woul d operate in accordance with NTL 2012

- JOINT

- G01 to reduce the potential for striking or disturbing these animals, and therefore no significant impacts are expected

.



### C.3. 6 Piping Plover (Threatened)

The Piping Plover ( Charadrius melodus ) is a migratory shor ebird that overwinters along the southeastern U.S. and Gulf of Mexico coasts. This threatened species is in decline as a result of hunting, habitat loss and modification, predation, and disease (USFWS, 2003). Critical overwintering habitat has been desig nated, including beaches in Texas, Louisiana, Mississippi, Alabama, and Florida ( Figure 3 ) . Piping Plovers inhabit coastal sandy beaches and mudflats, feeding by probing for invertebrates at or just below the surface. They use beaches adjacent to foragin g areas for roosting and preening (USFWS, 2010a). A species description is presented in a
recent lease sale EIS (MMS, 2007b).

A large oil spill (WCD) is the only IPF potentially affecting Piping Plovers. There are no IPFs associated with routine project activities that could affect these birds. A small fuel spill in the lease area would be unlikely to affect Piping Plovers beca use a small fuel spill would not be expected to make landfall or reach coastal waters prior to breaking up (see explanation in
Section A.9.2 ).Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 41

Figure 3. Location of selected environmental features in relation to the lease area.Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 42 

### Potential Impacts of a Large Oil Spill (WCD)

The lease area is 171 miles (275 km) from the nearest shorelines inhabited by Piping Plovers ( Figure 3 ). The OSRA results summarized in Table 3 indicate that Texas and Louisiana shorelines designated as critical habitat for the wintering Piping Plover could be contacted by a spill within
30 days. The highest probability of shoreline contact after 30 days is for Cameron Parish, Louisiana (3%)

. Plovers could physically oil themselves while foraging on oiled shores or secondarily conta minate themselves through ingestion of oiled intertidal sediments and prey (MMS, 2007b). Plovers congregate and feed along tidally exposed banks and shorelines, following the tide out and foraging at the water’s edge. It is possible that some deaths of P iping Plovers could occur, especially if spills occur during winter months when plovers are most common along the coastal Gulf or if spills contacted critical habitat. Impacts could also occur from vehicular traffic on beaches and other activities associated with spill cleanup. COP has extensive resources available to protect and rehabilitate wildlife in the event of a spill reaching the shoreline, as detailed in the OSRP.



### C.3. 7 Who oping Crane (Endangered)

The Whooping Crane ( Grus americana ) is an omnivorous wading bird and an endangered species. There are three wild populations in North America (Whooping Crane Eastern Partnership, 2010). One population winters along the Texas coast at Aransas NWR and
summers at Wood Buffalo National Park in Canada ; t his population represents the majority of the world’s population of free

- ranging Whooping Cranes and reached a record population of
270 at Aransas NWR in December 2008 (Whooping Crane E astern Partnership, 2010).
A nonmigrating population has been reintroduced in central Florida, and another reintroduced population summers in Wisconsin and migrates to the southeastern U nited States for the winter. Whooping Cranes breed, migrate, winter, and forage in a variety of habitats, including coastal marshes and estuaries, inland marshes, lakes, ponds, wet meadows and rivers, and agricultural fields (USFWS, 2007). About 9,000 ha (22,240 ac) of salt flats on Aransas NWR and adjacent islands compri se the principal wintering grounds of the Whooping Crane. Aransas NWR is designated as critical habitat for the species

. A species description is presented in a recent lease sale EIS (MMS, 2007b).

A large oil spill (WCD) is the only IPF potentially affec ting Whooping Cranes. A small fuel spill in the lease area would also be unlikely to affect Whooping Cranes, due to the distance from
Aransas NWR. As explained in Section A.9.2 , a small fuel spill would not be expected to make landfall or reach coastal waters prior to breaking up

.


### Potential Impacts of a Large Oil Spill (WCD)

A large oil spill is unlikely to affect Whooping Cranes as the lease area is approximately
358 miles ( 576 km) from its critical habitat designated in the Aransas NWR. The OSRA result s summarized in Section A.9.3 ( Table 3 ) predicts no contacts with shorelines of the Aransas NWR (Calhoun County, Texas) within 30 days. T he supplemental OSRA modeling (BOEM, 201 2 ) predicts that contact probabilities for Calhoun County range seasonally from <1% to 6% after
120 days.

In the event of oil exposure, Whooping Cranes could physically oil themselves while foraging in oiled areas or secondarily contaminate themselves through ingestion of contaminated shellfish, frogs, and fishes . It is possible that some Whooping Crane deaths could occur. In the event of aWalker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 43 spill, COP would work with the applicable State and Federal agencies to prevent impacts from a spill

.



### C.3. 8 Gulf Sturgeon (Threatened)

The Gulf sturgeon ( Acipenser oxyrinchus deso toi ) is a threatened fish species that today inhabits major rivers and inner shelf waters from the Mississippi River to the Suwannee River, Florida (Barkuloo, 1988; Wakeford, 2001). An anadromous fish that migrates from the sea upstream into coastal rivers to spawn in freshwater, it historically ranged from the Mississippi River to Charlotte Harbor, Florida (Wakeford, 2001). Populations have been depleted or even extirpated throughout this range by fishing, shoreline development, dam construction, water q uality changes, and other factors (Barkuloo, 1988; Wakeford, 2001). These declines prompted the listing of the Gulf sturgeon as a threatened species in 1991. The best known populations occur in the Apalachicola and Suwannee Rivers in Florida (Carr, 1996; Sulak and Clugston, 1998), the
Choct awhatchee River in Alabama (Fox et al.

, 2000), and the Pearl River in Mississippi/Louisiana (Morrow et al., 1998). Critical habitat in the Gulf extends from Lake Borgne, Louisiana (St. Bernard Parish) t o Suwannee Sound , Florida (Levy County) (NMFS, 2010 b) ( Figure 3 )

. A species description is presented in a recent lease sale EIS (MMS, 2007b) and in the recovery plan for this species (USFWS and Gulf States Marine Fisheries Commission, 1995)

. A large oil spill (WCD) is the only IPF potentially affecting Gulf sturgeon. There are no IPFs associated with routine project activities that could affect these fish. A small fuel spill in the lease area would be unlikely to affect Gulf sturgeon because a small fuel spill would not be expected to make landfall or reach coastal waters prior to breaking up (see explanation in
Section A.9.2 ).



### Potential Impacts of a Large Oil Spill (WCD)

Potential spill impacts on Gulf sturgeon are discussed in recent EISs ( MMS, 2007b, 2008 ; BOEMRE, 2011; BOEM, 2012 ) and by NMFS (2007)

. For this EP , there are no unique site

- specific issues with respect to this species.

The lease area is approximately 242 miles ( 389 km) from the nearest Gulf sturgeon critical
habitat. The OS RA modeling ( Table 3 ) estimates no contacts with coastal areas inhabited by Gulf sturgeon within 30 days. The additional OSRA modeling (BOEM, 201 2 ) predicts that a spill in the lease area has 2% or less probability of contacting any coastal areas inhabited by Gulf sturgeon within 120 days.

In the event of oil reaching Gulf sturgeon habitat, the fish could be affected by direct ingestion, ingestion of oiled prey, or the absorption of dissolved petroleum products through the gills.
Based on the life history of this species, subadult and adult Gulf sturgeon would be most vulnerable to an estuarine or marine oil spill, and would be vulnerable only from
1 September through 30 April when this species is foraging in estuarine and shallow marine habitats ( NMFS, 2007).



### C.3. 9 Beach Mice (Endangered)

Four subspecies of endangered beach m ouse ( Peromyscus polionotus ) occur on the barrier
islands of Alabama and the Florida Panhandle : the Alabama, Choctaw h atchee, Perdido Key, and
St. Andrew beach mice. Critical habitat has been designated for all four subspecies ; Figure 3Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 44 shows the critical habitat combined for all four subspecies . Species descriptions are provided in

a rece nt lease sale EIS (MMS, 2007b).

A large oil spill (WCD) is the only IPF potentially affec ting beach mice. There are no IPFs associated with routine project activities that could affect these animals due to the distance from shore and the lack of any onshore support activities near their habitat. A small fuel spill in
the lease area would not affect beach mice because a small fuel spill would not be expected to make landfall or reach coastal waters prior to breaking up (see Section A.9.2 ).



### Potential Impacts of a Large Oil Spill (WCD)

Potential spill impacts on beach mice are discussed in recent lease sale EISs (MMS, 2007b, 2008). For this EP , there are no unique site

- specific issues with respect to these species that were not analyzed in these documents.

The lease area is about 310 miles ( 499 km) northeast from the nearest beach mouse cri tical
habitat

. The OSRA modeling summarized in Section A.9.3 ( Table 3 ) predicts no contacts with Alabama and Florida shorelines inhabited by beach mice within 30 days. The additional OSRA modeling by BOEM (2012) predicts that a spill in the lease area ha s a 1 % or less probability of reaching either the Alabama or Florida shorelines inhabited by beach mice within 120 days.

In the event of oil contacting these beaches, beach mice could experience several types of direct and indirect impacts. Contact with spilled oil could cause skin and eye irritation and subsequent infection; matting of fur; irritation of sweat glands, ear tissues, and throat tissues; disruption of sight and hearing; asphyxiation from inhalation of fumes; and toxicity from ingestion of oil and contaminated food. Indirect impacts could include reduction of food supply, destruction of habitat, and fouling of nests. Impacts could also occur from vehicular traffic and other activities associated with spill cleanup. However, any such impacts are unlikely due to the distance from shore and response actions that would occur in the event of a spill.



## C.4 Coastal and Marine Birds

C.4.1 Marine Birds

Marine birds include seabirds and other species that may occur in the pelagic environment of the proj ect area (Clapp et al., 1982a,b, 1983; Peake, 1996; Hess and Ribic, 2000). Seabirds spend much of their lives offshore over the open ocean, except during breeding season when they nest along the coast. In addition, other birds such as waterfowl, marsh birds, and shorebird s may occasionally be present over open ocean areas. No endangered or threatened bird species are likely to occur at the project area due to the distance from shore. For a discussion of shorebird s and coastal nesting birds, see Section C.4.2

.
Seabirds of the northern Gulf of Mexico were surveyed from ships during the GulfCet II program. Hess and Ribic (2000) reported that terns, storm

- petrels, shearwaters, and jaegers were the most frequently sighted seabirds in the deepwater area. From these surveys, f our ecological categories of seabirds were documented in the deepwater areas of the Gulf: summer migrants (shearwaters, storm petrels, boobies); summer residents that breed in the Gulf (Sooty Tern, Least Tern, Sandwich Tern, Magnificent Frigatebird); winter residents (gannets, gulls, jaegers); and permanent resident species (Laughing Gulls, Royal Terns, Bridled Terns) (Hess and Ribic, 2000).Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 45 Common seabird species include Wilson’s S torm -P etrel ( Oceanites oceanicus ) , Magnificent Frigateb ird ( Fregata magnificens ), Northern Gannet ( Morus bassanus ), Masked Booby ( Sula dactylatra ), Brown Booby ( Sula leucogaster ), Cory’s Shearwater ( Calonectris diomedea ), Greater Shearwater ( Puffinus gravis ), and Audubon’s Shearwater ( Puffinus lherminieri ). S eabirds
are distributed Gulf

- wide and are not specifically associated with the lease area.

Relationships with hydrographic features were found for several seabird species, possibly due to effects of hydrography on nutrient levels and productivity of surface waters where birds forage.
The GulfCet II study did not estimate bird densities; however, Powers (1987) indicates that seabird densities over the open ocean typically are <10 birds/km 2

.

Trans

- Gulf migrant birds including shorebirds, wading birds, and terrestrial birds may also be present in the lease area. Migrant birds may use offshore structures and rigs for resting, feeding, or as temporary shelter from inclement weather (Russell, 2005). Some birds may be attracted to offshore structures because of the lights and the fish populations that aggregate
around these structures.

IPFs potentially affecting marine and pelagic birds include drilling rig presence, noise, and lights; support vessel and helicopter traffic; and two types of accidents – a small fuel spill and a large oil spill ( WCD ) . Effluent discharges are likely to have negligible impacts on the birds due to rapid dispersion, the small area of ocean affected, the intermittent nature of the discharges, and the mobility of these animals. Complian ce with NTL 2012

- BSEE

- G01 will minimize the potential for
marine debris

- related impacts on birds.



### Potential Impacts of Drilling Rig Presence, Noise, and Lights

Birds that frequent rig s may be exposed to contaminants including air pollutants and routine
dis charges, but significant impacts are unlikely due to rapid dispersion. Birds migrating over water have been known to strike offshore structures, resulti ng in death or injury (Wiese et al., 2001; Russell, 2005). Mortality of migrant birds at tall towers a nd other land

- based structures has been reviewed extensively, and the mechanisms involved in rig collisions appear to be similar. In some cases, migrants simply do not see a part of the rig until it is too late. In other cases, navigation may be disrupted by noise (Russell, 2005). On the other hand, offshore structures are suitable stopover habitats for most trans

- Gulf migrant species, and most of the migrants that stop over on rigs probably benefit from their stay, particularly in spring (Russell, 2005)

. Due to the limited scope and short duration of drilling activities described in this EP, any impacts on populations of either seabirds or trans

- Gulf migrant birds are not expected to be significant.

A recent study in the North Sea indicated that rig lighting causes circling behavior in various birds, especially on cloudy nights. Apparently the birds’ geomagnetic compass is upset by the red part of the spectrum from the lights currently in use (Nederlandse Aardolie Maatschappij, 2007). The numbers va ried greatly, from none at all to some tens of thousands of birds per night per rig, with an apparent effect radius of up to 3 miles (5 km). A study in the Gulf of Mexico also noted the phenomenon but did not recommend mitigation (Russell, 2005). In labo ratory experiments, Poot et al.

, (2008) found the magnetic compass of migratory birds to be wavelength dependent. Migratory birds require light from the blue

- green part of the spectrum for magnetic compass orientation, whereas red light (visible long

- wave length) disrupts their magnetic orientation. A field study was designed to test if and how changing light colorWalker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 46 influenced migrating birds under field conditions. It was found that nocturnally migrating birds were disoriented and attracted by red and whi te light (containing visible long

- wavelength radiation), whereas they were clearly less disoriented by blue and green light (containing less or no visible long

- wavelength radiation) (Poot et al., 2008) . Factors to consider in evaluating this impact in the Gulf of Mexico would include the lower incidence of cloudy and foggy days in the Gulf of Mexico versus the North Sea. Due to the limited scope and short duration of drilling activities proposed in this EP

, lighting impacts, collisions

, or other adverse effects are unlikely, and no significant impacts are expected.



### Potential Impacts of Support Vessel and Helicopter Traffic

Support vessels and helicopters are unlikely to significantly disturb pelagic birds in open, offshore waters. It is likely that indivi dual birds would experience, at most, only short

- term behavioral disruption

, and the impact would not be significant.



### Potential Impacts of a Small Fuel Spill

Potential spill impacts on marine birds are discussed in recent EISs (MMS, 2007b, 2008) . F or this

EP , there are no unique site

- specific issues with respect to spill impacts on these animals.

The probability of a fuel spill will be minimized by COP’s preventative measures during routine operations including fuel transfer. In the unlikely event of a sp ill, implementation of COP’s OSRP will reduce the potential for impacts on marine and pelagic birds

. EP Section H provides detail on spill response measures. Given the open ocean location of the lease area, the duration of a small spill and opportunity f or impacts to occur would be very brief.

A small fuel spill in offshore waters would produce a slick on the water surface and increase the concentrations of petroleum hydrocarbons and their degradation products. The extent and persistence of impacts would depend on the meteorological and oceanographic conditions at the time and the effectiveness of spill response measures. Section A.9.2 discusses the likely fate of a small fuel spill and indicates that over 90% would be evaporated or dispersed naturally

w ithin 24 hours. The area of the sea surface with diesel fuel on it would range from 0.5 to 5 ha (1.2 to 12 ac)

, depending on sea state and weather conditions.

Birds exposed to oil on the sea surface could experience direct physical and physiological effec ts including skin irritation; chemical burns of skin, eyes, and mucous membranes; and inhalation of toxic fumes. Due to the limited areal extent and short duration of water quality impacts from a small fuel spill, secondary impacts due to ingestion of oil via contaminated prey or reductions in prey abundance are unlikely. Due to the low densities of birds in open ocean areas, the small area affected, and the brief duration of the surface slick, no significant impacts on pelagic birds would be expected.



### Po tential Impacts of a Large Oil Spill (WCD)

Potential spill impacts on marine and pelagic birds are discussed in recent EISs (MMS, 2007b, 2008). For this EP , there are no unique site

- specific issues with respect to spill impacts on these
animals.

BOEM has reexamined the analys e s for coastal and marine birds presented in MMS (2007b, 2008) and determined that no new information was found that would alter the potential impact s on marine and pelagic birds (BOEMRE, 2011; BOEM, 2012).Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 47 Pelagic seabirds could be ex posed to oil from a spill at the project area. Hess and Ribic (2000) reported that terns, storm

- petrels, shearwaters, and jaegers were the most frequently sighted seabirds in the deepwater Gulf of Mexico (>200 m). Powers (1987) indicates that seabird
den sities over the open ocean typically are <10 birds/km 2 . The number of pelagic birds that could be affected in open, offshore waters would depend on the extent and persistence of the
oil slick.

The recent Macondo spill provides relevant information about the species of pelagic birds that may be affected in the event of a large oil spill. Birds that have been treated for oiling include several pelagic species such as the Northern Gannet

, Magnificent Frigatebird, and Masked Booby ( USFWS , 201 1b ). The Norther n Gannet is among the species with the largest numbers of birds affected by the spill.



### C.4.2 Shorebird s and Coastal Nesting Birds

Threatened and endangered bird species (Piping Plover and Whooping Crane) have been discussed previously in Section C.3 . Vari ous species of non

- endangered birds are also found along the northern Gulf C oast, including diving birds, shorebird s, marsh birds, wading birds, and waterfowl. Gulf Coast marshes and beaches also provide important feeding grounds and nesting habitats. Sp ecies that breed on beaches, flats, dunes, bars, barrier islands, and similar habitats include the Sandwich Tern, Wilson’s Plover, Black Skimmer, Forster’s Tern, Gull

- billed Tern, Laughing Gull, Least Tern, and Royal Tern (USFWS, 2010b). Additional inform ation is presented in recent lease sale EISs (MMS, 2007b, 2008).

The Brown Pelican ( Pelecanus occidentalis ) was delisted from Federal endangered status in 2009 (USFWS, 2010c). However, this species is listed as a species of greatest conservation need by

t he State of Mississippi (Mississippi Department of Wildlife, Fisheries and Parks, 2011) and as a species of special concern by the State of Florida (Florida Fish and Wildlife Conservation Commission, 2011 )

. Brown Pelicans inhabit coastal habitats and forage within both coastal waters and waters of the inner continental shelf. Aerial and shipboard surveys, including
GulfCet and GulfCet II, indicate that Brown Pelicans do not occur in deep offshore waters (Fritts and Reynolds, 1981; Peake, 1996; Hess an d Ribic, 2000). Nearly half the southeastern population of Brown Pelicans live s in the northern Gulf Coast, generally nesting on protected islands (USFWS, 2010 b ).

The Southern Bald Eagle ( Haliaeetus leucocephalus ) was delisted from its threatened status i n the lower 48 states on 28 June 2007. The Bald Eagle is a terrestrial raptor widely distributed
across the southern United States , including coastal habitats along the Gulf of Mexico. The Gulf
C oast is inhabited by both wintering migrant and resident Bald Eagles (Johnsgard, 1990;
Ehrlich et al., 1992).

IPFs potentially affecting shorebird s and coastal nesting birds include support vessel and helicopter traffic and a large oil spill (WCD). A small fuel spill in the lease area would be unlikely to affect shorebirds or coastal nesting birds because the lease area is 171 miles (275 km) from
the nearest shoreline (Louisiana) . As explained in Section A.9.2 , a small fuel spill would not be expected to make landfall or reach coastal waters prior to breaking up. Compliance with
NTL 2012

- BSEE

- G01 will minimize the potential for marine debris

- related impacts on shorebirds.Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 48 

### Potential Impacts of Support Vessel and Helicopter Traffic

Support vessels and helicopters will transit coastal areas near Port Fourchon and Am elia, Louisiana, where shorebird s and coastal nesting birds may be found. These activities could periodically disturb individuals or groups of birds within sensitive coastal habitats (e.g., wetlands that may support feeding, resting, or breeding birds).

Vessel traffic may disturb some foraging and resting birds. Flushing distances vary between species and between individuals (Rodgers and Schwikert, 2002). The disturbances will be limited to flushing birds away from vessel pathways; known distances are f rom 20 to 49 m (65 to 160 ft) for personal watercraft and 23 to 58 m (75 to 190 ft) for an outboard

- powered boat (Rodgers and Schwikert, 2002). Flushing distances may be similar or less for the support vessels to be used for COP’s project, and some specie s such as gulls are attracted to boats. Support vessels will not approach nesting or breeding areas on the shoreline, so disturbances to nesting birds, eggs, and chicks is not expected. Vessel operators will use designated navigation channels and comply with posted speed and wake restrictions while transiting sensitive inland waterways. Due to the limited scope and short duration of drilling activities, any short

- term impacts are not expected to be biologically significant to coastal bird populations.

Ai rcraft traffic can cause some disturbance to birds onshore and offshore. Responses are highly dependent on the type of aircraft, the bird species, the activities that animals were previously engaged in, and previous exposures to overflights (Efroymson et al., 2000). Helicopters seem to cause the most intense responses over other human disturba nces for some species (Bélanger and Bédard, 1989). However, Federal Aviation Administration Advisory Circular
No. 91

- 36D recommends that pilots maintain a minimum a ltitude of 610 m (2,000 ft) when flying over noise

- sensitive areas such as wildlife refuges, parks, and areas with wilderness characteristics. This is greater than the distance (slant range) at which aircraft overflights have been reported to cause behavi oral effects on most species of birds studied (Efroymson et al., 2000). With these guidelines in effect, it is likely that individual birds would experience, at most, only short

- term behavioral disruption.



### Potential Impacts of Large Oil Spill (WCD)

Data f rom the Macondo spill provide additional information about the species of coastal and
shore birds that may be affected in the event of a catastrophic spill of a similar nature and
duration. BOEM (2012) provides supplement al information to the analysis pre sented in the lease sale EIS (MMS, 2007b). As of May 12, 2011 (the last publicly available report on collected birds), USFWS (2011b) reported that 6,381 total birds were found dead or found alive and later died, of which an unknown number of deaths were a ttributable to the Macondo spill. According
to the USFWS (201 1b ), bird species that were treated for oiling include the following:

• Brown Pelican

• White Pelican

• Masked Booby

• Magnificent Frigatebird

• Laughing Gull

• Herring Gull

• Northern Gannet

• Black Crowned Night Heron

• Tri

- colored Heron • Green Heron

• Cattle Egret

• Snowy Egret

• Reddish Egret

• Least Bittern

• Common Tern

• Royal Tern

• Caspian Tern

• Sandwich TernWalker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 49 • Forster ’ s Tern

• Black Tern

• Gull

- billed Tern

• Least Tern

• Black Skimmer

• Common Loon

• Black Oystercatcher

• White Ibis

• Roseate Spoonbill • Willet

• Sanderling

• Dunlin

• Semipalmated Sandpiper

• Killdeer

• King Rail

• Clapper Rail

• Virginia Rail

According to the USFWS (2010d), species with the largest numbers of dead oiled birds were Laughing Gull, Northern Gannet, Brown Pelican, Royal Tern, Black Skimmer, Least Tern, unidentified Gull, and unidentified Tern. There are no reports of Bald Eagle oi ling.

While the Macondo spill had direct and indirect impacts to coastal and marine birds, it is premature to conclude impacts over a long period (BOEM, 2012). M odeling of Macondo spill

- related bird impacts is underway by the NRDA

, but results have not ye t been released.
Antonio et al. (2011) modeled bird mortality from the Macondo spill showing cumulative carcass numbers and mortality rate increasing exponentially from the start of the Macondo spill until the mortality rate began to decline after the 97t h day of the spill . Note that the collected animals would be a small subset of the total number of impacted birds and, therefore, the collected animals would represent an underestimated measure of the overall impact of the Deepwater Horizon event (BOEM

, 2012 ).

Coastal birds can be exposed to oil as they float on the water surface, dive during foraging, or wade in oiled coastal waters. Oiled birds can lose the ability to fly, dive for food, or float on the water, which could lead to drowning (USFWS, 2010 e). Oil interferes with the water repellency of feathers and can cause hypothermia in the right conditions. As birds groom themselves, they can ingest and inhale the oil on their bodies. Scavengers such as Bald Eagles and gulls can be exposed to oil by feeding on carcasses of contaminated fish and wildlife. While ingestion can kill animals immediately, more often it results in lung, liver, and kidney damage, which can lead to death. Bird eggs may be damaged if an oiled adult sits on the nest.

As noted above, the Brown Pelican was recently removed from the Federal endangered species list. Over 300 dead Brown Pelicans were collected in the Gulf following the Macondo spill, (USFWS, 2010d). These data indicate that Brown Pelicans may be particularly at risk of oiling in the event of a catastrophic spill reaching coastal waters. Issues for Brown Pelicans include direct contact with oil, disturbance by cleanup activities, and long

- term habitat contamination.



## C.5 Fisheries Resources

C.5.1 Pelagic Communities and Ichthyoplankton

Biggs and Ressler (2000) reviewed the biology of pelagic communities in the deepwater environment of the northern Gulf of Mexico. The biological oceanography of the region is dominated by the influence of the Loop Current, whose surfa ce waters are among the most oligotrophic in the world’s oceans. Superimposed on this low

- productivity condition are productive “hot spots” associated with entrainment of nutrient

- rich Mississippi River water and mesoscale oceanographic features. Anticyc lonic and cyclonic hydrographic features play anWalker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 50 important role in determining biogeographic patterns and controlling primary productivity in the northern Gulf of Mexico (Biggs and Ressler, 2000).

Most fishes inhabiting shelf or oceanic waters of the Gulf of Mexico have planktonic eggs and larvae (Ditty, 1986; Ditty et al., 1988; Richards et al., 1989, 1993). Pelagic eggs and larvae become part of the planktonic community for various lengths of time (10 to 100 days, depending on the species) (MMS, 2007b).

IPFs potentially affecting pelagic communities and ichthyoplankton include drilling rig presence, noise, and lights; effluent discharges; water intakes; and two types of accidents – a small fuel spill and a large oil spill ( WCD).



### Potential Impacts of Drill ing Rig Presence, Noise, and Lights

The drilling rig, as a floating structure in the deepwater environment, will act as a fish

- attracting device (FAD). In oceanic waters, the FAD effect would be most pronounced for epipelagic fishes such as tunas, dolphin , billfishes, and jacks, which are commonly attracted to fixed and drifting surface structures (Holland et al., 1990; Higashi, 1994; Relini et al., 1994 ; MMS, 2000, 2007b,
2008 ). This FAD effect could possibly enhance the feeding of epipelagic predators b y attracting and concentrating smaller fish species. Because the drilling rig is a single, temporary structure, impacts on fish populations, whether beneficial or adverse, are considered minor.



### Potential Impacts of Effluent Discharges

Treated sanitary and domestic wastes may have a slight effect on the pelagic environment in the immediate vicinity of these discharges. These wastes may have elevated levels of nutrients, organic matter, and chlorine, but should be diluted rapidly to undetectable levels with in tens to hundreds of meters from the source. Minimal impacts on water quality, plankton, and nekton are anticipated.

Deck drainage may have a slight effect on the pelagic environment in the immediate vicinity of these discharges. Deck drainage from con taminated areas will be passed through an
oil

- and

- water separator prior to release, and discharges will be monitored for visible sheen. The discharges may have slightly elevated levels of hydrocarbons but should be diluted rapidly to
undetectable levels w ithin tens to hundreds of meters from the source. Minimal impacts on water quality, plankton, and nekton are anticipated.

Other discharges in accordance with the NPDES permit, such as desalination unit brine and uncontaminated cooling water, fire water, and ballast water

, are expected to be diluted rapidly and have little or no impact on water column biota.



### Potential Impacts of Water Intakes

Seawater will be drawn from the ocean for once

- through, non

- contact cooling of machinery

on the drilling rig. The e stimated intake and discharge rate of cooling water is 140,000 BPD (5.88 MGD) and another 140,000 BPD (5.88 MGD) for fire water.

Section 316(b) of the Clean Water Act requires NPDES permits to ensure that the location, design, construction, and capacity of cooling water intake structures reflect the best technology
available to reduce the potential for adverse environmental impact s from impingement andWalker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 51 entrainment of aquatic organisms. All affected intakes will be in accordance with the design, monitoring, and recordkeeping re quirements of the NPDES permit.

The intake of seawater for cooling water will entrain plankton. The low intake velocity should allow most strong

- swimming juvenile fishes and smaller adults to escape entrainment or impingement. However, drifting plankton would not be able to escape entrainment with the exception of a few fast

- swimming larvae of certain taxonomic groups. Those organisms entrained may be stressed or killed, primarily through changes in water temperature during the route from cooling intake structure to discharge structure and mechanical damage (turbulence in pumps and condensers). Due to the limited scope and short duration of drilling activities , any short

- term impacts of entrainment are not expected to be biologically significant to plankton or ichthyoplankton populations.



### Potential Impacts of a Small Fuel Spill

Potential spill impacts on fi sheries resource s are discussed in recent EISs (MMS, 2007b, 2008)

. F or this EP , there are no unique site

- specific issues with respect to spill impacts.

The probability of a fuel spill will be minimized by COP’s preventative measures during routine operati ons including fuel transfer. In the unlikely event of a spill, implementation of COP’s OSRP will mitigate the potential for impacts on pelagic communities

, including ichthyoplankton.
EP Section H provides detail on spill response measures. Given the ope n ocean location of the lease area, the duration of a small spill and opportunity for impacts to occur would be very brief.

A small fuel spill in offshore waters would produce a slick on the water surface and increase the concentrations of petroleum hydrocarbons and their degradation products. The extent and persistence of impacts would depend on the meteorological and oceanographic conditions at the time and the effectiveness of spill response measures. Section A.9.2 discusses the likely fate of a small fuel spill and indicates that over 90% would be evaporated or dispersed naturally
within 24 hours. The area of the sea surface with diesel fuel on it would range from 0.5 to 5 ha (1.2 to 12 ac)

, depending on sea state and weather conditions.

A small fuel spill could have localized impacts on phytoplankton, zooplankton, and nekton. Due to the limited areal extent and short duration of water quality impacts, a small fuel spill would be unlikely to produce detectable impacts on pelagic communities.



### Potential Impacts of a Large Oil Spill (WCD)

A large oil spill could affect water column biota including phytoplankton, zooplankton, ichthyoplankton, and nekton. A large spill that persisted for weeks or months would be more likely to affect these communities. Wh ile adult and juvenile fishes may actively avoid a large spill, planktonic eggs and larvae would be unable to avoid contact. Eggs and larvae of fishes are especially vulnerable to oiling and they will die if exposed to certain toxic fractions of spilled o il. Impacts potentially would be greater if local

- scale currents retained planktonic larval assemblages (and the floating oil slick) within the same water mass.

The BOEM (2012) has reexamined the analysis for fish resources

, including ichthyoplankton, in consideration of the Macondo event. Although there remains incomplete or unavailable information on the impacts of the Macondo event, BOEM (2012) found there was n o substantialWalker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 52 new information that would alter the impact conclusions for fish resources and EFH presented in previous EISs (MMS, 2007a,b).



### C.5.2 Essential Fish Habitat

Essential Fish Habitat (EFH) is defined as those waters and substrate necessary to fish for spawning, breeding, feeding, and growth to maturity. Under the Magnuson

- Stevens Fis hery Conservation and Management Act, as amended, Federal agencies are required to consult on activities that may adversely affect EFH designated in Fishery Management Plans developed by the regional Fishery Management Councils.

The BOEM (2012) has reexamined the analysis for fish resources and EFH presented in recent lease EISs (MMS, 2007a,b) , in consideration of the Macondo event. No substantial new information was found that would alter the impact conclusions for fish resources and EFH presented in MMS (2007a,b).

The Gulf of Mexico Fishery Management Council (GMFMC) has prepared Fishery Management Plans for corals and coral reefs, shrimp s , stone crab, spiny lobster, reef fishes, coastal migratory pelagic fishes, and red drum. In 2005, the EFH for these managed species was redefined in Generic Amendment No. 3 to the various Fishery Management Plans (GMFMC, 2005). T he EFH for most of these GMFMC

- managed species is on the continental shelf in waters shallower than
183 m (600 ft). The shelf edge is the out er boundary for coastal migratory pelagic fishes, reef fishes, and shrimps. EFH for corals and coral reefs includes some shelf

- edge topographic features on the Texas

- Louisiana OCS, which is located 92 miles ( 148 km) north

- northwest of the
lease area.

Highly migratory pelagic fishes, which occur as transients in the lease area, are the only remaining group for which EFH has been identified in the deepwater Gulf of Mexico. Species in this group, including tunas, swordfishes, billfishes, and sharks, are managed by NMFS. Highly migratory species with EFH at or near the lease area include th e following species and life stages (NMFS, 2009):

• Albacore tuna (adults)

• Atlantic bigeye tuna (adults)

• Atlantic bluefin tuna ( spawn, eggs, larvae, adults)

• Blue marlin (juveniles, adults)

• Common thresher shark (all)

• Longbill spearfish (juveniles, adults) • Longfin mako shark (all)

• Oceanic whitetip shark (all)

• Skipjack tuna (spawn, adults)

• Swordfish (larvae, juveniles, adults)

• White marlin (juveniles, adults)

• Yellowfin tuna (spawn, juveniles, adults)

Recent research indicates the central and western Gulf of Mexico may be important spawning habitat for Atlantic bluefin tuna, and NMFS (2009) has designated a Habitat Area of Particular Concern (HAPC ) for this species. The HAPC covers much of the deepwater Gulf of Mexico, including the lease area ( Figure 3 ). The areal extent of the HAPC is approximately 300,000 km 2 (15,000 mi 2 ). The prevailing assumption is that Atlantic bluefin tuna follow an annual cycle of foraging in June through March off the eastern United States and Canadian coasts, followed by migration to the Gulf of Mexico to spawn in April, May, and June (NMFS, 2009).Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 53 On 27 May 2011, after an extensive scientific review, NMFS announced th at Atlantic bluefin tuna currently do not warrant species protection under the ESA (NMFS, 2011b)

. However,
NMFS classified the tuna as a species of concern, effectively placing it on a watch list as the agency awaits new data on the impact of a stricter i nternational management regimen

.

A new amendment to the original EFH Generic Amendment was finalized in 2005 (GMFMC, 2005). One of the most significant proposed changes in this amendment reduced the extent of EFH relative to the 1998 Generic Amendment by removing the EFH description and
identification from waters between 100 fathoms and the seaward limit of the Exclusiv e Economic Zone

. The Highly Migratory Species Fisheries Management Plan was amended in 2009 to update EFH and HAPC to include the bluefin tuna spawning area ( NMFS, 2009).

There are current NTLs (2009

- G39 and 2009

- G40) that provide guidance and clarificati on of the regulations with respect to biologically sensitive underwater features and areas and benthic
communities that are considered EFH (MMS, 2009 a,b ). A new EFH consultation has been initiated between BOEM’s Gulf of Mexico Region and NOAA’s Southeaste rn Region. Some
EFH requirements may change with the new agreement. Until the new agreement is in place, the 1999 Programmatic Consultation with the elements described a bove will be followed ( BOEMRE, 2011; BOEM, 2012 ).

Other HAPCs have been identified by the GMFMC (2005). These include the Florida Middle Grounds, Madison

- Swanson Marine Reserve, Tortugas North and South Ecological Reserves, Pulley Ridge, and several individual reefs and banks of the northwestern Gulf of Mexico ( Figure 3 ). The nearest of these is Jakkula Bank

, located approximately 103 miles (166 km)
north

- northwest of the lease area.

Routine IPFs potentially affecting EFH include drilling rig presence, noise, and lights; effluent discharges; water intakes; and two types of accidents – a small fuel spill and a large oil spill (WCD).



### Potential Impacts of Drilling Rig Presence, Noise, and Lights

The drilling rig, as a floating structure in the deepwater environment, will act as a n FAD.
In oceanic waters, the FAD effect would be most pronounc ed for epipelagic fishes such as tunas, dolphin, billfishes, and jacks, which are commonly attracted to fixed and drifting surface structures (Holland et al., 1990; Higashi, 1994; Relini et al., 1994 ; MMS, 2000, 2007b, 2008 ). This FAD effect would possibl y enhance feeding of epipelagic predators by attracting and concentrating smaller fish species. Because the drilling rig is a single, temporary structure, any impacts on EFH for highly migratory pelagic fishes are considered minor.



### Potential Impacts of Effluent Discharges

Other effluent discharges affecting EFH by diminishing ambient water quality include drilling muds and cuttings, treated sanitary and domestic wastes, deck drainage, and miscellaneous discharges such as desalination unit brine and unconta minated cooling water, fire water, and ballast water. Impacts on water quality have been discussed previously. No significant impacts
on EFH for highly migratory pelagic fishes are expected from these discharges.Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 54 

### Potential Impacts of Water Intakes

As noted previously, cooling water intake will cause entrainment and impingement of plankton, including fish eggs and larvae (ichthyoplankton). Due to the limited scope and short duration of drilling activities , any short

- term impacts on EFH for highly mi gratory pelagic fishes are not expected to be biologically significant.



### Potential Impacts of a Small Fuel Spill

The probability of a fuel spill will be minimized by COP’s preventative measures during routine operations including fuel transfer. In the unlikely event of a spill, implementation of COP’s OSRP will help diminish the potential for impacts on EFH. EP Section H provides detail on spill

response measures. Given the open ocean location of the lease area, the duration of a small spill and opportunity for impacts to occur would be very brief.

Potential spill impacts on EFH are discussed in recent EISs (MMS, 2007b, 2008)

. F or this EP

, there are no unique site

- specif ic issues with respect to spill impacts.

A small fuel spill in offshore waters would produce a slick on the water surface and increase the concentrations of petroleum hydrocarbons and their degradation products. The extent and persistence of impacts would depend on the meteorological and oceanographic conditions at the time and the effectiveness of spill response measures. Section A.9.2 discusses the likely fate of a small fuel spill and indicates that over 90% would be evaporated or dispersed naturally

w ithin 24 hours. The area of the sea surface with diesel fuel on it would range from 0.5 to 5 ha (1.2 to 12 ac)

, depending on sea state and weather conditions.

A small fuel spill could have localized impacts on EFH for highly migratory pelagic fishes,
incl uding tunas, swordfishes, billfishes, and sharks. These species occur as transients in the
lease area. A spill would also produce short

- term impact on water quality in the HAPC for spawning bluefin tuna, which covers much of the deepwater Gulf of Mexico. The areal extent of the affected area would represent a negligible portion of the HAPC.

A small fuel spill would not affect EFH for corals and coral reefs ; the nearest coral EFH is located
92 miles ( 148 km) north

- north west of the lease area . A small fue l spill would float and dissipate
on the sea surface and would not contact these features.



### Potential Impacts of a Large Oil Spill (WCD)

Potential spill impacts on EFH are discussed in recent EISs (MMS, 2007b, 2008). For this EP

, there are no unique site -s pecific issues with respect to EFH.

An oil spill in offshore waters would temporarily increase hydrocarbon concentrations on the water surface and potentially the subsurface as well. Given the extent of EFH designations in the Gulf of Mexico (GMFMC, 2005; NMFS, 2009), some impact on EFH would be unavoidable.

A large spill could affect the EFH for many managed species including shrimp s , stone crab, spiny lobster, reef fishes, coastal migratory pelagic fishes, and red drum. It would result in adverse impacts on water quality and water column biota including phytoplankton, zooplankton, and nekton. In coastal waters, sediments could be contaminated and result in persistent degradation of the seafloor habitat for managed demersal fish and shellfish speci es.Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 55 T he lease area is within the HAPC for spawning Atlantic bluefin tuna (NMFS, 2009). A large spill could temporarily degrade the HAPC due to increased hydrocarbon concentrations in the water column, with the potential for lethal or sublethal impacts on spawning tuna. Potential impacts would depend in part on the timing of a spill, as this species migrates to the Gulf of Mexico to spawn in April, May, and June (NMFS, 2009).

The closest sensitive habitat (topographic high, pinnacle area, or coral EFH) to the lease area is a
coral EFH

, located 92 miles ( 148 km) north

- north west of the lease area

. An accidental spill would be unlikely to affect this area, since a surface slick would not reach these features due to their depth.



## C.6 Archaeological Resources

C. 6.1 Shipwreck Sites

WR 416 and 460 are not on the list of lease blocks with a high potential for historic shipwrecks. As required by 30 CFR 550.194(a)(2), an archaeological assessment survey was conducted by Fugro (2012) which indicated that there is no e vidence of shipwrecks or other archaeological resources near the proposed surface locations.

Should there be any indication that potential shipwreck sites could be affected, in accordance
with NTL 2005

- G07

, COP will immediately halt operations, take steps to ensure that the site is not disturbed in any way

, and contact the BOEM Regional Supervisor, Leasing and Environment,
within 48 hours of its discovery. COP would cease all operations within 305 m (1,000 ft) of the site until the Regional Supervisor provides instructions on steps to take to assess the site’s potential historic significance and protect it.

Because there are no known shipwreck sites in the lease area, there are no routine IPFs that are likely to affect shipwrecks or other archaeological resources in these blocks. A small fuel spill would not affect shipwrecks because the oil would float and dissipate on the sea surface. Therefore, a large oil spill (WCD) is the only IPF considered.



### Potential Impacts of a Large Oil Spill (WCD)

MMS (2007 b) estimate d that a severe subsurface blowout could resuspend and disperse
sediments within a 300

- m (984

- ft) radius. Because there are no historic shipwrecks in the lease area, this impact would not be relevant.

Previous analyses (MMS, 2007a, 2008) conclu ded that oil spills would be unlikely to affect archaeological sites beyond the immediate vicinity of the wellhead (i.e., due to physical impacts of a blowout) because the oil would rise quickly to the sea surface directly over the spill location.
However , during the Macondo spill, subsurface plumes were reported at a water depth of about 1,100 m (3,600 ft), extending at least 22 miles ( 35 km ) from the wellsite and persisting for more than a month (Camilli et al., 2010). The subsurface plumes apparently r esulted from the use of dispersants at the wellhead (Joint Analysis Group, 2010c). While the behavior and impacts of subsurface plumes are not well known, a subsurface plume could have the potential to contact shipwreck sites beyond the 300

- m (984

- ft) rad ius estimated by MMS (2007a, 2008)

, depending on its extent, trajectory, and persistence. If oil from a subsea spill should come into contact with wooden shipwrecks on the seafloor

, it could adversely affect their condition or preservation.
Should there be any indication that potential shipwreck sites could be affected, COP will takeWalker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 56 appropriate steps to limit any potential impact and will contact the BOEM Regional Supervisor, Leasing and Environment within 48 hours of its discovery

.
A spill entering shallow coastal waters could conceivably contaminate an undiscovered shipwreck site. The OSRA modeling summarized in Table 3 predicts that Texas and Louisiana shorelines could be contacted by a spill within 30 days. A s noted by MMS (2007 b), should an oil spill contact a coastal historic site, such as a fort or a lighthouse, the major impact would be a temporary, reversible visual impact from oil contact and contamination of the site and its
environment.



### C.6.2 Prehistoric Archaeological Si tes

The wellsites are in wat er depth s ranging from 2,108 to 2,193 m (6,915 to 7,195 ft), which is well beyond the 60

- m (197

- ft) depth contour used by the BOEM as the seaward extent for prehistoric archaeological site potential in the Gulf of Mexico. Becau se prehistoric archaeological sites are not expected to be present in the lease area, the only relevant accident IPF is a large oil spill (WCD). A small fuel spill would not affect prehistoric archaeological
resources because the oil would float and dissi pate on the sea surface.



### Potential Impacts of a Large Oil Spill (WCD)

Because prehistoric archaeological sites are not expected to be present in the lease area, they would not be affected by the physical effects of a subsea blowout. The MMS (2007b) estima tes that a severe subsurface blowout could resuspend and disperse sediments within a 300

- m (984

- ft) radius.

Along the northern Gulf C oast, prehistoric sites occur frequently along the barrier islands and mainland coast and along the margins of bays and bay ous (MMS, 2007b). The OSRA modeling
summarized in Table 3 estimates that Texas and Louisiana shorelines could be contacted by a spill within 30 days and the 120

- day OSRA model estimates that Mississippi, Alabama, and
Florida coastlines could be contacted within 120 days

. If a spill did reach a prehistoric site along
these shorelines it could coat fragile artifacts or site features and compromise the potential for radiocarbon dating organic materials in a site (although other dating methods are available and it is possible to decontaminate an oiled sample for radiocarbon dating). Coastal prehistoric sites could also be damaged by spill cleanup operations (e.g., by destroying fragile artifacts and disturbing the provenance of artifacts and site features).



## C.7 Coastal Habitats and Protected Areas

Coastal habitats in the northeastern Gulf of Mexico that may be affected by oil and gas activities are described in recent EISs (MMS, 2007b, 2008) and in a literature review by Collard and Way (1997). Coastal habitats inshore of the project area include barrier beaches and dunes, wetlands, and submerged seagrass beds. Generally, most of the northeastern Gulf is fringed by barrier beaches, with wetlands and/or submerged seagrass beds occurring in sheltered area s behind the barrier islands and in estuaries.

Due to the distance from shore, the only IPF associated with routine activities in the lease area
that potentially may affect beaches and dunes, wetlands, seagrass beds, coastal wildlife refuges,
wilderness ar eas, or any other managed or protected coastal area is relate d to support vessel traffic. The primary support bases at Port Fourchon and Amelia, Louisiana are not in wildlifeWalker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 57 refuge s or wilderness area s . Potential impacts of support vessel traffic are addressed briefly
below.

A small fuel spill in the lease area would be unlikely to affect coastal habitats, as the lease area is
171 miles ( 275 km ) from the nearest shoreline (Louisiana) . As explained in Section A.9.2 , a small fuel spill would not be expect ed to make landfall or reach coastal waters prior to breaking up.



### Potential Impacts of Support Vessel Traffic

For OCS activities in general, support operations, including crew boats and supply boats, may have a minor incremental impact on coastal habitats or protected areas. Over time with a large number of vessel trips, vessel wakes can erode shorelines along inlets, channels, and harbors. Impacts will be minimized by following the speed and wake restrictions in harbors and channels.



### Potential Impacts of a Large Oil Spill (WCD)

Potential spill impacts on coastal habitats are discussed in recent EISs (MMS, 2007b, 2008). Coastal habitats inshore of the project area include barrier beaches and dunes, wetlands, and submerged seagrass beds. For this EP , ther e are no unique site

- specific issues with respect to
coastal habitats.

The OSRA modeling summarized in Table 3 predicts that shorelines of Texas and Louisiana could be affected within 30 days. Cameron Parish, Louisiana, has the highest potential of contact for
the 30

- day interval (3%). After 30 days, four Texas counties and four Louisiana parishes may be contacted, ranging from Matagorda County, Texas, to Plaquemines Parish, Louisiana (BOEM, 2012)

.
The shorelines within the geographic range predicte d by the OSRA modeling ( Table 3 ) include extensive barrier beaches and wetlands, with submerged seagrass beds occurring in sheltered
areas behind the barrier islands and in estuaries. NWRs and other protected areas along the
coast are discussed in a recen t lease sale EIS (MMS, 2007b) and COP’s OSRP. Coastal and near coastal wildlife refuges, wilderness areas , and State and National parks within the geographic range of the potential shoreline contacts within 30 days are presented in Table 6

.
Additional coastal areas could be contacted in the event of a spill persisting for more than
30 days. In the 12 0- day OSRA modeling (BOEM, 2012 ), potential shoreline contacts after
120 days ranged from Cameron County, Texas (at the Texas/Mexico border) to Dade County in southeastern Florida. These areas include habitats such as barrier beach and dune systems, wetlands, and submerged seagrass beds that support diverse wildlife, including endangered or threatened species. However, in the 120

- day OSRA modeling, counties o r parishes with greater than 10% contact probability during any season ranged from Matagorda County, Texas

, to Plaquemines Parish, Louisiana, which is identical to the geographic range identified in the
30

- day OSRA modeling.Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 58 Table 6. W ildlife refuges, wilderness areas, and S tate and N ational parks within the geographic range of the potential shoreline contacts within 30 days following an oil spill in the lease area. See Table 3 for contact probabilities of individual shoreline segments

.

County or Parish

, State W ildlife Refuge, Wilderness Area, or State/National Park

Matagorda County, Texas Big Boggy National Wildlife Refuge

Aransas National Wildlife Refuge
Mad Island Wildlife Management Area
San Bernard National Wildlife Refuge

Brazoria County, Texas San Bernard National Wildlife Refuge
Peach Point Wildlife Management Area
Brazoria National Wildlife Refuge Christmas Bay Coastal Preserve and Christmas Bay State Park

Galveston County, Texas Brazoria National Wildlife Refuge
Galveston Island State Park Apffel Park
Seawolf Park
Old Fort Travis Park
Atkinson Island Wildlife Management Area

Ft. Anahuac Park
Anahuac National Wildlife Refuge

McF addin National Wildlife Refuge Candy Abshier Wildlife Management Area
Atkinson Island Wildlife Management Area

Jefferson County, Texas McF addin National Wildlife Refuge
Sea Rim State Park

J.D. Murphree Wildlife Management Area
Texas Point National Wildlife Refuge

Cameron Parish, Louisiana Sabine National Wildlife Refuge
Cameron Prairie National Wildlife Refuge
Lacassine National Wildlife Refuge
Little Pecan Island Natural Area
Peveto Woods Natural Area Lower Neches Wildlife Management Area
Rockefeller Wildlife Management Area

Vermilion Parish, Louisiana Louisiana Rockefeller Wildlife Management Area Paul J. Rainey Wildlife Management Area

Terrebonne Parish, Louisiana Atchafalaya Delta Wildlife Management Area Mandalay National Wildlife Refuge Isles Dernieres Barrier Islands Refuge

Plaquemines Parish, Louisiana Salvador Wildlife Management Area
Delta National Wildlife Refuge

Pass A Loutre Wildlife Management Area

Breton National Wildlife Refuge

The level of impacts from oil spills on coastal habitats depends on many factors, including the oil characteristics, the geographic location of the landfall, and the weather and oceanographic conditions at the time (MMS, 2007b). Oil that makes it to beaches may be either liquid weathered oil, an oil

- and

- water mousse, or tarballs (MMS, 2007b). Oil is generally deposited on beaches in lines defined by wave action at the time of landfall. Oil that remains on the beach will thicken as its volatile components are lost. Thickened oil may form tarballs or aggregationsWalker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 59 that incorporate sand, shell, and other materials into its mass. Tar may be buried to varying depths under the sand. On warm days, both exposed and buried tarballs may liquefy and ooze. Oozing may also serve to expand the size of a mass as it incorporates beach materials. Oil on
beac hes may be cleaned up manually, mechanically, or both. Some oil can remain on the beach at varying depths and may persist for several years as it slowly biodegrades and volatilizes.

Wetlands are highly sensitive to oiling. The MMS (2007b) predicted that for every 50 bbl of oil contacting wetlands, approximately 2.7 ha (6.7 ac) of wetland vegetation will experience dieback. Thirty percent of these damaged wetlands are assumed to recover within 4 years, and 85% within 10 years. About 15% of the contacted wetlands are expected to be converted permanently to open

- water habitat. The critical concentration of oil is that concentration above which impacts to wetlands will be long

- term and recovery will take longer than two growing seasons, and which causes pla nt mortality and some permanent wetland loss. Critical concentrations of various oils are expected to vary broadly for wetland types and wetland plant species. Louisiana wetlands are assumed to be more sensitive to oil contact than elsewhere in the Gulf because of high cumulative stress (MMS, 2007b). In addition to the direct impacts of oil, cleanup activities in marshes may accelerate rates of erosion and retard recovery rates, which have been reported to require from years to decades following a spill (MMS, 2007b).

A blowout resulting in a large oil spill (WCD) is an extremely rare event, and the probability of such an event will be minimized by COP ’s well control and blowout prevention measures as
detailed in EP Section B

. In the unlikely event of a s pill, implementation of COP’s OSRP will
mit igate and reduce the impacts. EP Section H provide s detail on spill response measures. Therefore, no significant spill impacts on coastal habitats are expected.



## C.8 Socioeconomic and Other Resources

C.8.1 Recrea tional and Commercial Fishing

BOEM has reexamined the analysis for recreational and commercial fishing presented in
MMS (2007b, 2008) based on additional information and in consideration of the Macondo spill.
N o new information was found that would alter the potential impact s on commercial fishing (BOEMRE, 2011; BOEM, 2012)

.
The main commercial fishing activity in deep waters of the northern Gulf of Mexico is pelagic longlining for tunas, swordfishes, and other billfishes (Continental Shel f Associates, Inc., 2002). Pelagic longlining has occurred historically in the project area, primarily during spring and

summer. In August 2000, the Federal government closed two areas in the northeastern Gulf of Mexico to longline fishing (65 FR 47214, 1 August 2000). The lease is outside of the closure

areas.

Longline gear consists of monofilament line deployed from a moving vessel and generally allowed to drift for 4 to 5 hours (Continental Shelf Associates, Inc., 2002). As the mainline is put out, b aited leaders and buoys are clipped in place at regular intervals. It takes 8 to 10 hours to deploy a longline and about the same time to retrieve it. Longlines are often set near oceanographic features such as fronts or downwellings, w ith the aid of sop histicated on

- board temperature sensors, depth finders, and positioning equipment. Vessels typically are 10 to 30 m (33 to 98 ft) long, and their trips last from about 1 to 3 weeks. The main Gulf of MexicoWalker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 60 homeports for longlining vessels are in Louisian a (Dulac and Venice) and Florida (Destin, Madeira Beach, and Panama City).

It is unlikely that any commercial fishing activity other than longlining occurs at or near the project area. Benthic species targeted by commercial fishers occur on the upper cont inental slope, well inshore of the project area. Royal red shrimp ( Pleoticus robustus ) are caught by trawlers in water depths of about 250 to 550 m (820 to 1,804 ft). Tilefish es (primarily Lophalotilus chamaeleonticeps ) are caught by bottom longlining in water depths from about
165 to 450 m (540 to 1,476 ft) (Continental Shelf Associates, Inc., 2002).

Most recreational fishing activity in the region occurs in water depths less than 200 m (656 ft) (Continental Shelf Associates, Inc., 1997, 2002). In de eper water, the main attraction to recreational fishers would be petroleum rig s offshore Texas and Louisiana. Due to the distance from shore, it is unlikely that recreational fishing activity is occurring in the lease area.

The only routine IPF potentiall y affecting fisheries is drilling rig presence (including noise and lights). Two types of potential accidents are also addressed below – a small fuel spill and a large oil spill (WCD).



### Potential Impacts of Drilling Rig Presence

There is a slight possibility of pelagic longlines becoming entangled in the drilling rig. For example, in January 1999, a portion of a pelagic longline snagged on the acoustic Doppler current profiler of a drillship working in the Gulf of Mexico (Continental Shelf Associates, Inc.

, 2002). The line was removed without incident. Generally, longline fishers use radar and are aware of offshore structures and ships when placing their sets. Therefore, little or no impact on pelagic longlining is expected.

Because it is unlikely that any recreational fishing activity is occurring in the project area, no adverse impacts are anticipated. Other factors such as effluent discharges are likely to have negligible impacts on commercial or recreational fisheries due to rapid dispersion, the sma ll area of ocean affected, and the intermittent nature of the discharges.



### Potential Impacts of a Small Fuel Spill

The probability of a fuel spill will be minimized by COP’s preventative measures during routine operations including fuel transfer. In the un likely event of a spill, implementation of COP’s OSRP will potentially mitigate and reduce the potential for impacts. EP Section H provide s detail on spill response measures. Given the open ocean location of the lease area, the duration of a small spill and opportunity for impacts to occur would be very brief.

Pelagic longlining activities in the lease area, if any, could be interrupted in the event of a small fuel spill. The area of the sea surface with diesel fuel on it would range from 0.5 to 5 ha (1. 2 to 12 ac)

, depending on sea state and weather conditions. Fishing activities could be interrupted due to the activities of response vessels operating in the lease area. A small fuel spill would not affect coastal water quality because the spill would n ot be expected to make landfall or reach coastal waters prior to breaking up (see Section A.9.2 ).Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 61 

### Potential Impacts of a Large Oil Spill (WCD)

Potential spill impacts on fishing activities are discussed in recent EISs (MMS, 2007b, 2008). For
this EP, there are no unique site

- specific issues with respect to this activity.

Pelagic longlining activities in the lease area and other fishing activities in the northern Gulf of Mexico could be interrupted in the event of a large oil spill. A spill may or may not result in fishery closures, depending on the duration of the spill, the oceanographic and meteorological conditions at the time, and the effectiveness of spill response measures. The recent Macondo spill provides information about the maximum potentia l extent of fishery closures in the event of a large oil spill in the Gulf of Mexico (NMFS, 201 1c ). At its peak on 2 June 2010, closures encompassed 8 8, 522 mi 2 ( 229,270 km 2 ), or 3 6.6 % of the U.S. Exclusive Economic Zone in the Gulf of Mexico. BOEM (2012) notes that fisheries closures from a large spill event could have a negative effect on short

- term fisheries catch and/or marketability.

The BOEM (2012) reexamined the analysis for impacts to commercial fish resources presented
in recent lease sale EISs (M MS, 2007b, 2008) and found that no substantial newly published,

peer

- reviewed information was found that would alter the overall conclusion that the potential impacts on commercial and recreational fishing activities from an accidental oil spill are
antici pated to be minimal because the potential for oil spills is very low, because most events are small and of short duration, and because the effects are so localized that fishes are typically able to avoid the affected area. Fish populations may be affected by an oil spill event should it occur, but they would be primarily affected if the oil reaches the productive shelf and estuarine areas where many fishes spend a portion of their life cycle. The probability of an offshore spill affecting these nearshore environments is also low. BOEM (2012) concludes that impacts on catch or value of catch would be insignificant compared with natural variability and other pressures affecting the resource.



### C.8.2 Public Health and Safety

There are no IPFs associated with r outine operations that are expected to affect public health and safety. Impacts of a small fuel spill and a large oil spill (WCD) are addressed below.



### Potential Impacts of a Small Fuel Spill

The probability of a fuel spill will be minimized by COP’s preve ntative measures during routine operations including fuel transfer. In the unlikely event of a spill, implementation of COP’s OSRP will potentially alleviate the potential for impacts. EP Section H provide s detail on spill response

measures.

A small fuel spill would not have any impacts on public health and safety because it would affect only a small area of the open ocean 171 miles ( 275 km) from the nearest shoreline (Louisiana) and nearly all of the diesel fuel would evaporate or disperse naturally within 24 hours. Response crews would be equipped with appropriate safety equipment to avoid injury and health effects. A small fuel spill would not be expected to make landfall or reach coastal waters prior to breaking up (see Section A.9.2 ).Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 62 

### Po tential Impacts of a Large Oil Spill (WCD)

In the event of a large spill from a blowout, the main safety and health concerns are those of the offshore personnel involved in the incident and those responding to the spill. The drilling rig maintains a Shipb oard Oil Pollution Emergency Plan as required under MARPOL 73/78.

Depending on the spill rate and duration, the physical/chemical characteristics of the oil, meteorological and oceanographic conditions at the time, and the effectiveness of spill response

m easures, the public could be exposed to oil on the water and along the shoreline, including skin contact or breathing VOCs . Crude oil is a highly flammable material

, and any smoke or vapors from a crude oil fire can cause irritation, and in large quantiti es may pose a health
hazard.

Data from the recent Macondo spill provide relevant information about the types of health issues that may occur in the event of a large oil spill

. Initial symptoms from cleanup workers who sought medical care in Louisiana were typical of acute exposure to hydrocarbons or H 2 S

, e.g., headaches, dizziness, nausea, vomiting, cough, respiratory distress, and chest pain (Solomon and Janssen, 2010). Wildlife cleaning and rehabilitation workers reported concerns including scrapes and cuts, itchy or red skin or rash, and symptoms of headache or feeling faint, dizzy, or fatigued (King and Gibbins, 2011). Hand, shoulder, or back pain was also reported by some wildlife cleaning workers. Awkward postures, repetitive motions, and heavy lifting tasks were noted by investigators as contributing to musculoskeletal symptoms. However, the most common occupational hazard identified for spill response workers was heat stress from work in a hot and humid environment (King and Gibbins, 2011).

A blo wout resulting in a large oil spill (WCD) is an extremely rare event, and the probability of such an event will be minimized by COP ’s well control and blowout prevention measures as
detailed in EP Section H . In the unlikely event of a spill large enough to require extensive use of subcontracted cleanup labor

, compliance with COP’s OSRP and subcontractor HSE requirements as well as NOAA and the Occupational Safety and Health Administration ( OSHA ) requirements will e liminated or minimize the p otential for such adv erse impacts to the work force.



### C.8.3 Employment and Infrastructure

There are no IPFs associated with routine operations that are expected to affect employment and infrastructure. The project involves drilling with support from existing shorebase facilities in
Louisiana . No new or expanded facilities will be constructed, and no new employees are expected to move permanently into the area. The project will have a negligible impact on socioeconomic conditions such as local employment, existing offshore and coastal infrastructure (including major sources of supplies, servic es, energy, and water), and minority and lower income groups. Impacts of a small fuel spill and a large oil spill (WCD) are addressed below.



### Potential Impacts of a Small Fuel Spill

The probability of a fuel spill will be minimized by COP’s preventative me asures during routine operations

, including fuel transfer. In the unlikely event of a spill, implementation of COP’s
OSRP will potentially mitigate and reduce the potential for impacts. EP Section H provide s detail on spill response measures. Given the open ocean location of the lease area, the duration of a small spill and opportunity for impacts to occur would be very brief.Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 63 A small fuel spill that is dissipated within a few days would have little or no economic impact, as the spill response would use existing facilities, resources, and personnel.



### Impacts of a Large Oil Spill (WCD)

Potential socioeconomic impacts of an oil spill are discussed in recent EISs (MMS, 2007b, 2008).
For this EP , there are no unique site

- specific issues with respect to employment and coastal infrastructure. A large spill could cause economic impacts in several ways: it could result in extensive fishery closures that put fishermen out of work; it could result in temporary employment as part of the response effort; it could result in adverse publicity that affects employment in coastal recreation and tourism industries; and it could result in another suspension of OCS drilling activities, including service and support operations that are an important part of local economie s.

The lease area is 171 miles (2 75 km) from the nearest shoreline. Based on the 30

- day
OSRA modeling as summarized in Table 3 , as well as the 120

- day modeling by BOEM (2012)

, Texas and Louisiana coastal areas have the most potential to be affected by a spill. Potential shoreline contacts after 120 days range from Cameron County, Texas (at the Texas/Mexico border) to Dade County in southeastern Florida (BOEM, 2012)

.
In addition to the analys e s presented by MMS (2007b, 2008 ) and BOEM (2012 ), a recent study explored the economic impacts of the Macondo spill on oil and gas industry employment due to suspension of deepwater drilling (Inter

- Agency Economic Report, 2010). The study indicates that during the moratorium, the number of oil industry workers in the Gulf of Mexico fell by about 2,000 and may have indirectly caused a temporary loss of 8,000 to 12,000 jobs along the Gulf Coast. Total spending by drilling operators is estimated to have declined by $1.8 billion
over a six

- month period; this direct reduction in spending affected employment in the industries that supply the Gulf drilling industry and in all other industries affected by declines in consumer and business spending (Inter

- Agency Economic Report, 2010)

.
As noted by BOEM (2012) , the short

- term so cial and economic consequences for the Gulf coast region should a large spill occur include the opportunity cost of employment and expenditures that could have gone to production or consumption rather the spill cleanup efforts. Nonmarket effects such as traffic congestion, strains on public services, shortages of commodities or services, and disruptions to the normal patterns of activities or expectations could also occur in the short term. These negative, short

- term social and economic consequences of a spill are expected to be modest in terms of projected cleanup expenditures and the number of people employed in cleanup and remediation activities (BOEM, 2012) . Net employment impacts from a spill would not be expected to exceed 1% of baseline employment in any given year (BOEM, 2012)

.



### C.8.4 Recreation and Tourism

BOEM has reexamined the analys e s for recreation and tourism presented in MMS (2007b, 2008)
based on additional information and in consideration of the Macondo oil spill event. N o new information was found that would alter the potential impact s on recreation and tourism ( BOEMRE, 2011; BOEM, 2012 ).

There are no known recreational uses of the lease area. Recreational resources and tourism in coastal areas would not be affected by any routine activi ties due to the distance from shore.Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 64 Compliance with NTL 2012

- BSEE

- G01 will minimize the chance of trash or debris being lost overboard from the drilling rig and subsequently washing up on beaches.



### Potential Impacts of a Small Fuel Spill

The probability of a fuel spill will be minimized by COP’s preventative measures during routine operations including fuel transfer. In the unlikely event of a spill, implementation of COP’s OSRP will potentially help mitigate and reduce the potential for impacts

. EP Section H provide s detail on spill response measures. Given the open ocean location of the lease area, the duration of a small spill and opportunity for impacts to occur would be very brief.

A small fuel spill in the lease area would be unlikely to affect recreation and tourism. There are no known recreational or tourism activities occurring in the lease area, and as explained in
Section A.9.2 , a small fuel spill would not be expected to make landfall or reach coastal waters prior to breaking up.



### Impacts of a Large Oil Spill (WCD)

Potential impacts of an oil spill on recreation and tourism are discussed in recent EISs (MMS, 2007b, 2008 ; BOEM, 2012 ). For this EP , there are no unique site

- specific issues with respect to these impacts.

Impacts o n recreation and tourism would vary depending on the duration of the spill and its fate including the effectiveness of response measures. A large spill that reached coastal waters and shorelines could adversely affect recreation and tourism by contaminati ng beaches and wetlands, resulting in negative publicity that encourages people to stay away. Based on the
30

- day OSRA modeling as summarized in Table 3 , as well as the 120

- day OSRA modeling by BOEM (2012), Texas and Louisiana shorelines are the areas wit h the most potential to be contacted by a spill. However, potential shoreline contacts af ter 120 days range from
Cameron County, Texas (at the Texas/Mexico border) to Dade County in southeastern Florida (BOEM, 2012)

. According to BOEM (2012), should an oi l spill occur and contact a beach area or other recreational resource, it would cause some disruption during the impact and cleanup phases of the spill. However, these effects may be small in scale and of short duration depending on the size of the spill and the extent of the contact. In the unlikely event that a spill occurs that is sufficiently large enough to affect large areas of the coast and, through public perception, have effects that reach beyond the damaged area, effects to recreation and touris m could be significant (BOEM, 2012)

. In addition to the analysis presented by MMS (2007b, 2008) and BOEM (2012) , recent and ongoing studies have explored the economic impacts of the Macondo spill including tourism and “brand” damage (IEM, 2010; Oxford Economics, 2010). The U.S. Travel Association has estimated the economic impact of the Macondo spill on tourism across the Gulf Coast o ver a three

- year period at $22.7 billion (Oxford Economics, 2010).



### C.8.5 Land Use

Land use along the northern Gulf C oast is discussed in recent lease sale EISs (MMS, 2007b, 2008 ; BOEM, 2012 ). There are no routine IPFs potential ly affecting land use. The project will use existing onshore support facilities in Louisiana . The land use at the existing shorebase sites isWalker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 65 industrial. The project will not involve any new construction or changes to existing land use and, therefore, will not have any impacts. Levels of boat and helicopter traffic, as well as demand for goods and services including scarce coastal resources, will represent a small fraction of the level of activity occurring at the shorebase s.

A large oil spill (WCD) is the only relevant accident I PF. A small fuel spill would not have any impacts on land use, as the response would be staged out of existing shorebases and facilities.



### Potential Impacts of a Large Oil Spill (WCD)

The initial response for a large oil spill would be staged out of existing facilities, with no effect on land use. A large spill could have limited temporary impacts on land use along the coast if additional staging areas were needed. For example, during the Macondo spill, temporary staging areas were established in Louisiana, Mississippi, Alabama, and Florida for spill response and cleanup efforts. In the event of a large spill in the lease area, similar temporary staging areas could be needed. These areas would eventually return to their original use as the

response is demobilized.

According to BOEM (2012)

, there is low probability that an accidental oil spill will significantly affect land use and coastal infrastructure in the region, in part because an offshore spill would have a small probability of contacting ons hore resources.



### C.8.6 Other Marine Uses

The lease area is not located within any USCG

- designated fairway or shipping lane. The lease area is not located within a Military Warning Area

. There are no existing man

- made seabed
infrastructures within 610 m (2,000 ft) of the proposed wellsites ( Gardline , 2012).

There are no IPFs from routine project activities that are likely to affect other marine uses of the lease area. A large oil spill (WCD) is the only relevant accident IPF. A small fuel spill would no t have any impacts on other marine uses because spill response activities would be mainly within
the lease area and the duration would be brief.



### Potential Impacts of a Large Oil Spill (WCD)

An accidental spill would be unlikely to significantly affect shipping or other marine uses. The block s are not located within any USCG

- designated fairway or shipping lane. In the event of a large spill requiring numerous response vessels, coordination would be required to manage the vessel traffic for safe operati ons. COP will comply with BOEM requirements and lease stipulations to avoid impacts on uses of the area by military vessels and aircraft.



## C.9 Cumulative Impacts

For purposes of NEPA, cumulative impact is defined as “the impact on the environment which

res ults from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non

- Federal) or person undertakes such other actions” (40 CFR 1508.7). Any single activity or action may have a negligible impact(s) by itself, but when combined with impacts from other activities in the same area and/or time period, substantial impacts may result.Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 66 Prior Studies . The BOEM and MMS also recently analyzed the cumulative impacts of
O CS development activities similar to those planned in this EP in several documents. The level and types of activities planned in COP 's EP are within the range of activities described and
evaluated in the Final EIS for Gulf of Mexico OCS Oil and Gas Lease Sales 2007

- 2012: Western Planning Area Sales 204, 207, 210, 215, and 218, and Central Planning Area Sales 205, 206, 208, 213, 216, and 222 (MMS, 2007b), as updated by a 2008 Final Supplemental EIS for Gulf of
Mexico OCS Oil and Gas Lease Sales 2009

- 2012: C entral Planning Area Sales 208, 213, 216, and 222 and Western Planning Area Sales 210, 215, and 218 (MMS, 2008) , as well as Final Supplemental EIS for Gulf of Mexico OCS Oil and Gas Lease Sale 2012: Central Planning Area
Sale 216 / 222 (BOEM, 2012) . Past, p resent, and reasonably foreseeable activities were identified in the cumulative effects scenario. These documents are incorporated by reference.

Cumulative Impacts of Activities in the Initial EP

The BOEM (2012) Central Planning Area lease sale EIS analyzed the environmental and socioeconomic impacts from the proposed lease sale, OCS program, and other activities affecting the resour ces, ecosystems, and human environment other than the proposed action including both human

- induced and natural phenomena. The cumulative impacts analysis provides a discussion of all impacts (including non

- OCS activities) projected to occur from past,

pro posed, and foreseeable future activities that have taken or will take place within the geographic area of the Central Planning Area during the 4 0- year period of 2010 to 2050. . The MMS (2007b) multi

- lease

- sale EIS included a lengthy d iscussion of cumulative impacts, which analyzed the environmental and socioeconomic impacts from the incremental impact of the 11 proposed lease sales, in addition to all activities (including non

- OCS activities) projected to occur from past, proposed, and future lease sales during the 40

- year period of 2007 to 2046 (see EIS page 4- 301). The EIS considered exploration, delineation, and development wells; platform installation; service

- vessel trips; and oil spills. The EIS examined the potential cumulative effects on each specific resource for the
entire Gulf of Mexico.

The level and type of activity proposed in COP ’s Initial EP are within the range of activities
described and evaluated in the recent multi

- lease

- sale EISs and Central Planning Area EIS

. T he numerous new safety measures implemented by the BOEM and BSEE and the mitigation and safety measures proposed by COP in its Initial EP reduce the likelihood of a large spill and improve the effectiveness of any response in the extremely unlikely event that another large spill occurs. Thus, for all impacts, the incremental contribution of COP ’s proposed actions to the cumulative impacts analysis in these prior analyses is not significant.



## D. Environmental Hazards

D.1 Geologic Hazards

Well clearance letters prepared by Gardline (2012) concluded that the wellsites are free of any significant geological hazards and are suitable for the proposed activi ties. See EP Section C for supporting geological and geophysical information.Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 67 

## D.2 Severe Weather

Under most circumstances, weather is not expected to have any effect on the proposed activities. Extreme weather, including high winds, strong currents, and large waves, was considered in the design criteria for the drilling rigs under consideration for this project . High winds and limited visibility during a severe storm could disrupt support activities (vessel and helicopter traffic) and make it necessary to suspend some activities on the drilling rig for safety reasons until the storm or weather event passes. In the event of a hurricane, procedures as
outlined in the Hurricane Evacuation Plan would be adhered to.



## D.3 Currents and Waves

Metocean conditions such as sea states, wind speed, ocean currents, etc., will be continuously
monitored. Under most circumstances, physical oceanographic conditions are not expected to have any effect on the proposed activities. Strong currents (e.g., caused by Loop Current eddies and intrusions) and large waves were considered in the design criteria for the drilling rig s under consideration for this project. High waves during a severe storm could disrupt support activities (i.e., vessel and helicopter traffic) and make it necessary to suspend some activities on the drilling rig for safety reasons until the storm or weather event passes.



## E. Alternatives

N o formal alternatives we re evaluated in this EIA for an EP . However, various technical and operational options

, including alternate wellsite locations and the selection of a drilling unit, were considered by COP in developing the proposed action.



## F. Mitigation Measures

The proposed action includes numerous mitigation measures required by laws, regulations, and
BO EM lease stipulations and NTLs. The project will comply with all applicable F ederal, S tate, and local requirements concerning air pollutant emissions, discharges to water, and solid waste disposal. All project activities will be conducted under guidance by COP’s OSRP and will include
the measures described in EP Section H

.



## G. Consultation

No persons or agencies were consulted during the preparation of this EIA.Walker Ridge Blocks 416 and 460 August 2012 Environmental Impact Analysis for Initial Exploration Plan Page 68 

## H. Preparers

The EIA was prepared by CSA International, Inc. Contributors included

• Deborah Fawcett (Project Scientist 2);

• Neal Phillips, Ph.D. (Senior Scientist);

• Keith VanGraafeiland (GIS/Remote Sensing Specialist);

• Kristen L. Metzger (Library and Information Services Director ) ; and

• Kim Dunleavy (Technical Editor).



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### SECTION P ADMINISTRATIVE INFORMATION

(A) EXEMPTED INFORMATION DESCRIPTION The proposed bottom-hole locations of the planne d wells have been rem oved from the Public Information copies of the EP as well as any inform ation concerning the target objectives, geologic or geophysical data, and any interprete d geology or subsurface information.

(B) BIBLIOGRAPHY 1. Gardline Surveys, Inc. 3D Geohazard Assessment Walker Ridge Blocks 416, 417, 460 and 461. 2. Fugro Geoservices, Inc. Archaeological Assessment Walker Ridge Blocks 416, 417, 460 and 461. Report No. 2412-5002.

ConocoPhillips Company August, 2012 Initial Exploration Plan Page P-1 Walker Ridge Blocks 416 and 460 (OCS-G 32678 and OCS-G 32688)