Bird Strike Avoidance and Lighting Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. i March 2015

Bird Strike Avoidance and Lighting Plan

Chukchi Sea, Alaska

March 2015

Shell Gulf of Mexico Inc.

3601 C Street, Suite 1000

Anchorage, AK 99503
Bird Strike Avoidance and Lighting Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. ii March 2015

Table of Contents

Page

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

1.1 Background.................................................................................................................1

1.2 Proposed Exploration Plan..........................................................................................1

1.3 Endangered Species Act, Migratory Bird Treaty Act, and Lease Stipulation ...........3

1.3.1 Endangered Species Act .................................................................................3

1.3.1.1 Steller’s Eider...................................................................................3

1.3.1.2 Spectacled Eider...............................................................................4

1.3.2 Migratory Bird Treaty Act..............................................................................4

1.3.3 Lease Stipulations...........................................................................................4

1.4 Relative Risk Evaluation.............................................................................................5

2.0 REVIEW OF MITIGATION MEASURES............................................................................9

2.1 Low Reflecting Finishes.............................................................................................9

2.2 Minimum Vessel Light ...............................................................................................9

2.3 Light Color..................................................................................................................9

2.4 Anti-Collision Lighting.............................................................................................10

2.5 Radar Assessment .....................................................................................................10

3.0 PROPOSED MITIGATION .................................................................................................11

3.1 Bird Strike Monitoring..............................................................................................11

3.2 Lighting Protocols.....................................................................................................13

3.2.1 Shading and Minimization............................................................................13

3.3 Vessel and Aircraft Traffic .......................................................................................13

4.0 REFERENCES .....................................................................................................................14

Figures

Figure 1.1 Location Map ................................................................................................................2

Figure 1.4-1 Spectacled Eider Densities and Critical Habitat .........................................................7

Figure 1.4-2 Steller's Eider Densities...............................................................................................8

Attachments

Attachment A – Stipulation No. 7, Oil and Gas Lease Sale 193, Chukchi Sea

Attachment B – Avian Collision Form
Bird Strike Avoidance and Lighting Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. iii March 2015

ACRONYMS

BOEM Bureau of Ocean Energy Management

EP Revision 1 Chukchi Sea Exploration Plan Revision 1 (Shell 2011) 

EP Revision 2 Chukchi Sea Exploration Plan Revision 2 (Shell 2015)

ESA Endangered Species Act

ft. feet/foot

hr(s) hour(s)

km kilometer(s)

LBCHU Ledyard Bay Critical Habitat Unit

m meter(s)

MBTA Migratory Bird Treaty Act

MHz Megahertz

mi statute mile(s)

PSO Protected Species Observer

MMS U.S. Department of the Interior, Minerals Management Service

M/V Motor Vessel

OCS Outer Continental Shelf 

Plan Bird Strike Avoidance and Lighting Plan

Shell Shell Gulf of Mexico Inc.

U.S.C. United States Code

USFWS U.S. Fish and Wildlife Service
Bird Strike Avoidance and Lighting Plan Chukchi Sea, Alaska

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1.0 INTRODUCTION

1.1 Background

This document comprises Shell Gulf of Mexico Inc.’s (Shell) Bird Strike Avoidance and Lighting Plan, 

Chukchi Sea, Alaska and applies to Shell’s exploration drilling program as detailed in the Chukchi Sea

EP Revision 2. The Plan meets all the requirements of Stipulation No. 7 under the Chukchi Sea Lease 

Sale 193 (MMS 2008a).

Growing scientific evidence indicates some bird species are attracted to light sources, which may increase 

the risk of bird strikes. Most related studies conclude that increased darkness, coupled with inclement 

weather, increases attraction by birds to lighted vessels and structures. Birds drawn to light often become 

disoriented and can then collide with these structures resulting in injury and death. 

There is specific concern for threatened spectacled (Somateria fischeri) and Steller’s (Polysticta stelleri) 

eiders. The chance of an eider strike occurring on the drilling units during Shell’s exploration drilling 

program is considered low (d’Entremont et. al 2013), because the drill sites are more than 64 statute miles 

(mi) (103 kilometers [km]) offshore (Figure 1.1) in an area of the Chukchi Sea with low eider densities

(LGL 2010; Gall and Day 2012); d’Entremont et. al 2013) and because of the length of daylight during 

the exploration drilling season. Nevertheless, Shell will implement the Plan to minimize the chance of 

bird strikes occurring during exploration drilling operations. 

Emphasis of the Plan is on preventing bird strikes by spectacled and Steller’s eiders that may be present in 

the Chukchi Sea during the period of operations and may, occasionally, venture into the area near Shell’s 

exploration drilling operations. In addition, the Plan includes reporting requirements for any bird strikes,

which will help to better understand the risks of bird strikes associated with drilling units. 

1.2 Proposed Exploration Plan

Shell plans to continue an exploration drilling program on its leases in the Chukchi Sea Planning Area of 

the Outer Continental Shelf (OCS). Shell’s leases were acquired in Oil and Gas Lease Sale 193 (Figure 

1.1). Shell plans to drill exploration wells on lease blocks within its Burger Prospect. The locations of the

lease blocks are indicated in Figure 1.1. These activities started in 2012. Each drilling season spans the 

summer and fall (July-October) when migratory birds may be present.

The drilling units Noble Discoverer and the Polar Pioneer will be used to drill the wells. The drilling 

units will be attended by vessels that may be used for ice management, anchor handling, oil spill response 

(OSR), refueling, resupply, and servicing of the drilling operations. 

The drilling units and support vessels anticipate transiting through the Bering Strait into the Chukchi Sea 

on or about 1 July, arriving on location in Shell’s prospect on or about 4 July.

1 Exploration drilling will 

commence as ice, weather, and other conditions safely allow, and could continue until on or about 31 

October.

 

1 As noted in the EP Revision 2, Shell may request permission to transit through the Bering Strait prior to 1 July. 
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Figure 1.1 Location Map
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1.3 Endangered Species Act, Migratory Bird Treaty Act, and Lease 

Stipulation

The exploration activities proposed in Shell’s EP Revision 2 are subject to the Endangered Species Act 

(ESA), the Migratory Bird Treaty Act (MBTA), and the Bureau of Ocean Energy Management’s (BOEM)

Lease Stipulation No. 7, which requires offshore operators to implement certain measures to minimize the 

likelihood of exploration affecting spectacled and Steller’s eiders. Shell has prepared this plan in response 

to these statutory requirements. This plan represents a practical approach towards using appropriate 

mitigation measures to reduce potential avian collisions between Shell vessels and the threatened eider 

species and other migratory birds in the activity area.

1.3.1 Endangered Species Act 

The purpose of the ESA is to conserve “the ecosystems upon which endangered and threatened species 

depend” and to conserve and recover listed species. Under the law, species may be listed as either 

“endangered” or “threatened.” Endangered means a species is in danger of extinction throughout all, or a 

significant portion of, its range. Threatened means a species is likely to become endangered within the 

foreseeable future. All species of plants and animals, except pest insects, are eligible for listing as 

endangered or threatened (USFWS 2006a). The law requires federal agencies, in this case BOEM, to 

consult with the U.S. Fish and Wildlife Service (USFWS) to ensure that the actions they authorize would 

not jeopardize listed species or adversely modify or destroy any designated critical habitat.

Section 7 of the ESA requires federal agencies to ensure that their actions do not jeopardize the continued 

existence of listed species or adversely modify or destroy any designated critical habitat. To comply with 

Section 7, the consulting federal agency, or its designated non-federal representative, must review the 

proposed project for potential impacts to protected species. The two species listed under the ESA that this 

plan is intended to help protect are the Steller’s eider and the Spectacled eider.

1.3.1.1 Steller’s Eider

The Alaska-breeding population of Steller’s eider was federally designated as threatened in 1997 and is 

an Alaska Species of Special Concern. Historically, Steller’s eiders nested throughout the coastal areas of 

western and northern Alaska (USFWS 2005b). Today, the Alaska breeding population is primarily 

confined to the Arctic Coastal Plain in low densities and is extremely scarce in western Alaska (USFWS 

2005b). The Steller’s eider may have abandoned much of the eastern North Slope in recent decades, but 

still occur in low densities from Wainwright to as far east as Prudhoe Bay (USFWS 2003). The threatened 

Alaska breeding population is thought to be in the hundreds or low thousands on the Arctic Coastal Plain 

and in the dozens on the Yukon Kuskokwim Delta (USFWS 2005b). The species also occurs in Russia; 

although not precisely known, the Russian Atlantic population is thought to be 30,000 to 50,000 

individuals, and the Russian Pacific population 50,000 to 100,000 (USFWS 2005b).
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1.3.1.2 Spectacled Eider

The spectacled eider was federally designated threatened throughout its range in 1993 and is an Alaska 

Species of Special Concern. The breeding distribution of the spectacled eider includes the central coast of 

the Yukon-Kuskokwim Delta, the Arctic Coastal Plain of Alaska, and the Arctic Coastal Plain of Russia 

(USFWS 2005b). Spectacled eiders on the Arctic Coastal Plain of Alaska originally ranged to the 

Canadian border (USFWS 1996). The threatened spectacled eider population is estimated to be about 

360,000 worldwide, which includes non-breeders (USFWS 2005b). The population may be in slow 

decline on the Arctic Coastal Plain of Alaska, where 3,000 to 4,000 nest today (USFWS 2005b). At least 

40,000 pairs are thought to nest in Arctic Russia. Molting flocks of spectacled eiders gather in shallow 

waters off the coast in usually less than 120 ft. (36 meters [m]) deep and travel along the coast up to 31 mi 

(50 km) offshore (Peterson et al 1999).

1.3.2 Migratory Bird Treaty Act

Under the MBTA (16 United States Code [U.S.C.] 703), it is illegal for anyone to "take" migratory birds, 

their eggs, feathers or nests. “Take” includes by any means or in any manner, any attempt at hunting, 

pursuing, wounding, killing, possessing or transporting any migratory bird, nest, egg, or part thereof. The 

MBTA does not distinguish between intentional and unintentional take. In Alaska, some species of 

migratory birds may be taken, killed, or possessed during approved hunting seasons for those specified 

migratory species.

1.3.3 Lease Stipulations

Lease Stipulation No. 7 (full text provided in Attachment A of the Plan) for the Chukchi Sea Lease Sale 

193 Area is intended to minimize the likelihood of spectacled and Steller’s eiders striking drilling 

structures or vessels. The stipulation has 4 parts as discussed below:

Part A(1) mandates that EPs for exploration drilling programs include a plan for recording and reporting 

bird strikes. This component of the stipulation applies to exploration drilling programs located anywhere 

in the Chukchi Sea Planning Area, and therefore applies to Shell’s program.

Parts A(2) and B(2) place travel restrictions and lighting protocol requirements on vessel and aircraft 

operations when they take place in certain listed blocks, in federal waters shoreward of those blocks, and 

in the Ledyard Bay Critical Habitat Unit (LBCHU), during specific dates. The listed blocks are shown in 

Figure 1.1 (as lease blocks under Stipulation No. 7) and are listed at the end of Attachment A of this 

document. These stipulation components would apply to any aircraft or vessels that are part of Shell’s

exploration drilling program under EP Revision 2 (and presumably any future revision), if and when the 

vessels or aircraft are in the identified parts of the Chukchi Sea.

Part B(1) places lighting protocol requirements on drilling structures in the Chukchi Sea. This stipulation 

requirement applies to drilling structures operating on a lease or staged anywhere in the Chukchi Sea 

Planning Area, and therefore applies to Shell’s drilling units.
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The above-referenced travel restrictions or conditions and lighting protocol restrictions are summarized 

below:

General Conditions

 Lessees must include a plan for recording and reporting bird strikes that occur during approved 

activities to BOEM.

 Vessels associated with the exploration drilling activities should avoid traversing listed blocks 

(stipulation area), and federal waters between the stipulation area and shore, to the maximum 

extent possible between 15 April and 10 July. If such traffic cannot be avoided, hazing equipment 

must be onboard.

 Except during emergencies or for safety, vessels must avoid travel within the LBCHU between 1 

July and 15 November. Any required travel in this area must be reported to BOEM within 24 

hours (hr).

 Aircraft supporting the exploration drilling operations must avoid operating below an altitude of 

1,500 ft. (457 m) over the stipulation area and federal waters between the stipulation area and 

shore between 15 April and 10 June, or the LBCHU between 1 July and 15 November, to the 

maximum extent possible. If weather does not permit these altitudes then the flight should take 

place along a BOEM/USFWS-approved pre-determined flight path. Any deviations from the path 

due to safety or other issues must be reported within 24 hr.

Lighting Protocols

 Lessees are required to prepare a plan that identifies measures that will be undertaken to 

minimize the likelihood that migrating and coastal birds will strike exploration drilling structures 

(drilling units), and obtain approval for the plan from BOEM. The plan must include measures 

that reduce the radiation of light outward from the drilling units to minimize the likelihood that 

birds will strike the structure.

 Surface support vessels must minimize the use of high-intensity work lights, especially while 

traversing the stipulation area and federal waters between the stipulation area and the coastline. 

Exterior lights must be used only as necessary to illuminate on-deck work areas during periods of 

darkness or inclement weather. Interior lights and lights used during navigation may remain on 

for safety.

The lighting requirements and protocols in this plan apply to activities conducted between 15 April and 

15 November.

1.4 Relative Risk Evaluation

The risk of bird collision is largely determined by the timing and location of exploration activities in 

relation to the presence of spectacled and Steller’s eiders in the Chukchi Sea. Spectacled and Steller’s 

eiders nest onshore across the coastal North Slope. The distribution and density of breeding eiders on the 

North Slope are indicated in Figure 1.4-1 and Figure 1.4-2.

The Alaska-breeding population of the Steller’s eider is primarily confined to the Arctic Coastal Plain of 

Alaska’s North Slope, with a concentration of nesting eiders around Barrow (USFWS 2005a, Figure 

1.4-2). Their use of offshore waters of the northeastern Chukchi Sea can be generally discussed in terms 

of spring migration and post-breeding, which includes fall migration and molting. 
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Spring migration of eiders in the Chukchi Sea occurs in May and June (MMS 2007a,b; MMS 2008b). The 

migration occurs along the coastal waters (MMS 2006), where many marine birds use the lead system as a 

migratory pathway to breeding grounds in northern Alaska and the Canadian Arctic (Richardson and 

Johnson 1981, Woodby and Divoky 1982). Eiders may also migrate overland during spring as they move 

to the eastern North Slope from the Chukchi Sea (Troy Ecological Research Associates 1999 cited in 

MMS 2003). Offshore exploration drilling operations in the Chukchi Sea would begin on or about 4 July, 

which is after spring migration has ended.

Post-breeding spectacled and Steller’s eiders generally move to the marine environment where they molt 

and start their fall migration. However, their movement to the marine environment varies by sex and 

timing. Males and some females with failed nests leave nesting areas for marine waters in late June or in 

July (MMS 2006). Successful female Steller’s eiders and their broods gather near the coast later in the 

summer (MMS 2006) and some successful female spectacled eiders stay with their young on the nesting 

grounds until late August to early September, at which time they start their southward migration (USFWS 

2005a).

Molting flocks of spectacled eiders gather in shallow waters, usually less than 120 ft. (36 m) deep, and 

travel along the coast up to 30 mi (50 km) offshore (Peterson et al. 1999). Critical habitat for the 

spectacled eider includes Ledyard Bay (i.e., LBCHU), a large offshore area northeast of Cape Lisburne. 

This area is used for molting by spectacled eiders from July through October (USFWS 2005a). Other 

important molting and staging areas in the Chukchi Sea include Peard Bay and Kasegaluk Lagoon 

(Petersen et al. 1999). These areas are outside and shoreward of the lease blocks where the proposed 

exploration drilling program is scheduled to occur. No habitat on the North Slope has been designated as 

critical for the Steller’s eider (USFWS 2005a).

Fall migration of spectacled and Steller’s eiders has been documented by telemetry studies. Spectacled 

eiders were found to winter in a dense concentration within Norton Sound and fall migrations have been 

documented to go through the critical habitat described above (Petersen et al. 1999). Telemetry studies 

have shown Steller’s eiders leaving the Arctic Coastal Plain nesting areas near Barrow on 23 June for the 

coastal marine waters between Wainwright and Dease Inlet between Cape Lisburne and Point Lay (MMS 

2006). Eight individuals were tracked from Barrow across the Chukchi Sea to Siberia and back to Alaska 

(MMS 2006).

Spectacled and Steller’s eiders will be most widely distributed in the Chukchi Sea during the post-nesting 

period. Although the majority of the eiders are likely stay close to the coast where they migrate and molt, 

some may be encountered far from shore within the exploration drilling areas. In the Chukchi Sea, 

proposed exploration drilling operations would begin no earlier than July and would be at least 96 km (60 

mi) offshore in water depths of 130-150 ft. (40-46 m). Steller’s eiders would not be expected to occur in 

Shell’s Burger Prospect, but a small number of spectacled eiders may be found in there during the time 

period when exploration drilling is planned. Bird surveys were conducted in the Burger Prospect area in 

July-October in 2009 and 2010 as part of a series of baseline studies. One spectacled eider was observed 

in the Burger Prospect during two years of these intensive surveys, and no Steller’s eiders were recorded 

(Gall and Day 2009, 2010).

In addition to the risk of bird strikes being minimized by the timing and location of exploration drilling 

operations, the high amount of daylight hours experienced in the area during the months of July and 

August also reduces the relative risk of bird strikes. Later in the season (September and October), 

the bird strike risk may increase due to reduced daylight hours; however, bird densities tend to be lower 

during these months potentially offsetting the effects of the reduced daylight hours. 
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Figure 1.4-1 Spectacled Eider Densities and Critical Habitat
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Figure 1.4-2 Steller's Eider Densities
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Shell Gulf of Mexico Inc. 9 March 2015

2.0 REVIEW OF MITIGATION MEASURES

A literature review of existing mitigation measures used in Alaska and the lower 48 states was conducted 

to assess the efficacy of existing mitigation to reduce the chances of bird strikes. The studies were 

reviewed to determine what mitigation measures would be appropriate for use during Shell’s exploration 

drilling program in the Chukchi Sea. None of the studies are specific to either the spectacled eider or the 

Steller’s eider. Most of the work to date deals with documenting bird collisions with communication 

towers in the lower 48 states or seabirds with fishing vessels in the Aleutian Islands of Alaska. Light 

sources, especially from taller structures exceeding 200 ft. (60.9 m) and during periods of low visibility, 

are implicated in many bird collisions. The following is a brief summary of measures considered by Shell 

with regard to mitigating the effects of light on birds and reducing avian collisions. The effectiveness of 

some of these measures has not been studied, and some studies that have been conducted are not

conclusive. Shell recognizes the need to reduce vessel light emissions to lower the risk of bird strikes, 

and has selected the most proven and practical measures for the Plan. 

2.1 Low Reflecting Finishes

Painting vessels a dark color would decrease ambient reflected light, thus reducing light output beyond 

the deck. The amount of light reduced by such an action is unknown. Another option is to paint 

alternating and contrasting colors, which may allow a vessel to be more easily seen by birds. No studies 

evaluating the effects of low reflecting finishes are available for review, therefore the efficacy of these 

measures is unknown.

2.2 Minimum Vessel Light

Birds can be disoriented by and attracted to artificial lights, potentially resulting in injury and mortality if 

a collision occurs. Organizations working on reducing bird mortality, such as Bird Life International, 

include minimizing vessel light use (without compromising vessel worker safety) in their general 

recommendations for reducing bird strikes. This has proven effective in some situations. For a lighthouse, 

narrowing and decreasing light intensity resulted in a drastically lower bird mortality rate from an average 

of 200.6-18.5 birds per season during spring and 392.5-9.6 birds during fall (Jones and Francis 2003). 

Minimization of light can include shading, directing lights towards the deck, avoiding the use of

unnecessary lights, and using minimal light output through the replacement of high intensity lights.

2.3 Light Color

It is likely that any light visible to humans is visible to birds, and thus constitutes a potential attractant 

(Verheijen 1985). Different colors of light (wavelengths) have been considered as mitigation to reduce 

bird strikes. Research in the North Sea has indicated that white light caused attraction, red light caused 

disorientation, and that green and blue light caused a weak response (Marquenie 2007). White lights in 

this study were replaced with specially designed lights that excluded the red spectrum and appeared green 

(Marquenie 2007). The green lights resulted in 2 to 10 times fewer birds circling offshore platforms when 

only a limited number of light sources were replaced with green lights. Therefore the results likely 

underestimate the effect that would occur if all external lights were replaced with green lights (Marquenie 

2007).
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2.4 Anti-Collision Lighting

The effects of anti-collision lighting systems at Northstar Island were studied for four years for eiders and 

other birds (e.g. gulls, loons, geese) found in the Beaufort Sea (Day et al. 2005). Analysis of the data 

revealed some statistically significant responses and some weak responses by eiders to the anti-collision 

lights. In general, results of the analyses indicate a net movement of eiders away from the island, and a 

significant slowing of the eiders flight speed at night. The lights clearly did not cause non-eider species to 

avoid the island and actually appeared to cause attraction at times. Eiders exhibited a natural anti-collision

response to the island, which the strobe lights were thought to increase modestly. Day et al. (2005) 

concluded the anti-collision lights caused some eiders to avoid Northstar Island, but the avoidance 

response was not consistent and was not dramatic. The effectiveness of the anti-collision lights in 

reducing the risk of eider collisions was not clear, and the lights did not appear to deter other non-eider 

species at all. The following summarizes the lighting system used at Northstar (Day et al. 2005):

 14 white strobe lights (Honeywell Flashguard 2000B strobe lights) are mounted on tall masts 

approximately 13.7 m (45 ft.) above the ocean surface around Northstar Island

 Each strobe light is set to flash at the rate of 40 flashes/minute

 The strobe lights are not set to flash in pattern or synchrony

 The strobe lights emit white light (all wavelengths) at 20,000 candlepower during the day and 

2,000 candlepower during the night

 Photocell controls the switching between the two modes

Anti-collision lights may vary by wavelength, flashing rate, flashing synchrony, and intensity. Some 

evidence exists that passerines may avoid white lights better than red lights (Manville 2005). White strobe 

lights are considered less likely to attract night-migrating birds than non-flashing white and red lights 

(New Mexico Department of Game & Fish 2001). However, the appropriate light wavelength is unknown 

for best deterring eiders and a continued search for a lighting system that is more effective than the one 

used at Northstar Island is recommended by Day et al. (2005).

2.5 Radar Assessment

Radar can be used to examine the impact and collision risk of birds with man-made structures. It is a tool 

that has been used for decades to study birds and track bird movements in a three dimensional space and 

time. Radar can detect birds that are beyond the visual limit of observers and it is a particularly useful 

tool when visual observations are limited by darkness, fog, or precipitation. Radar in this respect can be a 

valuable monitoring tool to help better understand the risks to birds and can used to make informed 

decisions about whether mitigation efforts (e.g., changes to lighting) are required.

There are limitations to consider when using radar. Radars do not have the ability to determine the 

species of a bird, however; tracks can be assigned to taxa on the basis of flight speed (Larkin and 

Thompson 1980) and other variables captured within the return signal echo. During periods of high 

precipitation and or other radar-clutter causing events (e.g. high sea states), detecting small targets, such 

as birds, can be challenging.

There are several types of radar that have been used to study bird movements, from low-powered airport 

surveillance radars and mobile marine surveillance radars to high-powered weather radars and military 

tracking radars. Each type of radar has characteristics that make it suitable for its particular application 

(tracking features, range, cost, etc.). In 2005, a German team investigated the avian avoidance response to 

offshore wind turbines using the radar system Furuno FR2125 (Desholm and Kahlert 2005). The species 

involved in that analysis were primarily common eider (Somateria mollissima) and geese. In another 

study (Gauthreaux and Livingston 2006), the VERTRAD/TI radar system was used to estimate the 
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Shell Gulf of Mexico Inc. 11 March 2015

potential collision risk of migrating birds with man-made obstacles of various heights. Another system 

(BIRDRAD) was able to detect the departure of migrants from different types of habitat within a few 

kilometers of the radar (Gauthreaux and Belser 2005). This system used a high resolution, marine 

surveillance radar (Furuno 2155 BB) with a 50-kilowatt transceiver. Gauthreaux and Belser (2005) also

discussed the use of WSR-88D Doppler Weather Surveillance Radar to characterize bird echoes to better

understand bird migration rates. Overall, radar has many applications making it a valuable tool to help 

better understand bird movements in relationship to specific conservation concerns. 

3.0 PROPOSED MITIGATION 

Based upon the mitigation measures reviewed in Section 2.0, Shell has identified a suite of appropriate 

mitigation measures for use during Shell’s exploration drilling program in the Chukchi Sea.

2

 The 

mitigation proposed by Shell is based on what is currently and technically feasible and proven effective, 

in reducing the prospect of bird strikes, while fully considering the lighting requirements needed to 

maintain a safe work environment. Additional mitigation may be considered as more information 

becomes available regarding the effectiveness of new mitigation to reduce the risk of bird strikes.

Given the location of Shell’s exploration program, impacts from bird strikes with vessels likely would 

affect only small numbers of individuals with no significant effects at the population level for any species. 

Implementing the mitigation measures as specified in this Plan will reduce the probability of bird strikes

associated with Shell’s planned activities. 

Shell has prepared this Plan to reduce the chance of bird strikes of the drilling units, especially strikes by 

spectacled and Steller’s eiders. The major elements of the Plan are provided below:

 Bird strike monitoring that includes recording and reporting bird strikes for the collection of 

information on bird strikes and lighting configuration and a better understanding of methods 

to reduce bird strikes. 

 Shading and directing some drilling unit lights inward and downward to living and work 

structures to minimize the amount of light radiating from the drilling units.

 Minimizing the use of high-intensity work lights on support vessels.

 Restricting aircraft and vessel travel routes and flight altitudes.

3.1 Bird Strike Monitoring 

The overall objective of bird strike monitoring is to provide the USFWS with data for risk assessment of 

bird strikes related to operational activities and weather conditions, with a focus on threatened eiders. If 

bird strikes are determined to be a serious risk to birds despite the proposed mitigation measures 

presented in this document, Shell will evaluate additional mitigation measures for future offshore 

activities. 

All mortalities and injuries from strike events of a spectacled or Steller’s eider will be reported to the 

Alaska OCS Regional Office of the BOEM and the Ecological Services Branch of the USFWS in 

Anchorage within three days of the event or as soon as is practicable. This includes any collisions 

associated with the drilling units, support vessels, and associated aircraft. Other pertinent information 

that may help better understand the risk of bird strikes will be sent to the USFWS after the end of the 

drilling season. 

The following data will be collected upon a determination that a bird strike has occurred:

 

2 The bird strike avoidance measures that Shell intends to implement are consistent with those that have been 

required in the past by BOEM and the USFWS.
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 Description of event

 Bird species, if can be determined

 Environmental conditions (at time of strike if known)

 Visibility

 Ambient light conditions

 Beaufort wind force

 Weather

 Date and time (of strike if known)

 Vessel lighting conditions

 Vessel location

 Bird Injury Status or Carcass Condition

 Photographs if practicable 

Shell will conduct daily routine deck searches for live, injured birds, or dead birds, especially during or 

following periods of darkness (i.e., daybreak) or inclement weather such as rain or fog. Protected Species 

Observers (PSOs) can assist with deck searches; however, PSOs will need to follow the vessels safety 

policy on restricted areas and PPE requirements. Birds perching on ship structures (such as antennae and 

rigging) will be allowed to rest and depart on their own.

Any observed bird strike shall be documented and reported within three days to BOEM. If a bird strikes 

and remains on the vessel, it will be photographed (if possible) and left there to recover and depart on its 

own. If necessary to take it out of harm’s way, it will be moved to a dry place from where it can depart 

on its own. If the bird does not depart after about 12 hr and is still alive, it will be gently returned to the 

sea surface. Shell will consult with the USFWS to further determine the proper handling of injured birds 

in the event of a bird strike. Carcasses from any lethal strikes will be photographed (if possible) and 

returned to the sea. Photographs will be taken of the bird with wings spread, top and bottom views, and 

of the head, to assist with species verification and will be submitted to BOEM and USFWS as part of the 

bird strike report.

Strike information will be recorded on the Avian Collision Form provided in Attachment B of this Plan. 

An avian observer or PSO with training in bird identification will collect the data associated with any bird 

strike. Placards will be posted in common areas to inform all personnel to report dead or injured birds. 

This will increase awareness and the likelihood that data will be recorded. The observer will have 

equipment such as a bird identification guide, a flashlight, and a camera to help with data collection. 

Although Shell will make every effort to record all bird strikes; it is recognized that some bird strikes may 

not be noticed. Eiders often fly low and fast over water, which suggests that they could possibly strike 

the hull of the drilling units and fall into the water unobserved. In addition, darkness and inclement 

weather can make visual observations difficult. 
Bird Strike Avoidance and Lighting Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. 13 March 2015

3.2 Lighting Protocols

Much of the drilling units lighting will be directed inward and downward, where practical, to minimize 

escaping light. Additionally, some lights will be fitted with shading that will direct lights to working 

areas and prevent light escaping to areas where lights are not needed for safety and operations. When 

practical, lights will be turned off when not in use.

3.2.1 Shading and Minimization

Shell plans to reduce or shade light output from the following locations on the drilling units:

 Deck lighting, doorway and stairway lighting, and pipe rack lighting: lights will be shaded to 

direct light downward and inward and/or the wattage reduced.

 Crane boom lights: lights to remain unshielded for safety during crane operations. 

 Heliport lighting: lights to be dimmed or shut off when not in use.

 Navigation and clearance lights: no change will be made due to safety concerns.

 Lights from windows: shades will be used during darkness.

Shell will minimize the use of high-intensity work lights on the support vessels, especially when 

traversing the stipulation area and federal waters between the stipulation area and the shoreline. Exterior 

lights will be used on these vessels only as necessary to illuminate on-deck work areas during periods of 

darkness or inclement weather. Otherwise the lights will be turned off. Interior lights and lights used for 

navigation will remain on for safety.

3.3 Vessel and Aircraft Traffic

Surface vessels associated with exploration drilling operations will avoid operating or traversing within 

the LBCHU between 1 July and 15 November as much as possible (except for emergencies or 

human/navigation safety). Vessels that do enter into the LBCHU (Figure 1.1) during this time period for 

emergencies or human/navigation safety will report the information to BOEM within 24 hr.

Aircraft supporting exploration drilling operations will avoid operating below 1,500 ft. (457 m) above sea 

level over the LBCHU (Figure 1.1) between 1 July and 15 November as practicable. Pre-designated 

flight routes, which will be approved by the USFWS and BOEM during review of the exploration plan, 

may be used if the area must be traversed and weather prevents attaining an altitude of 1,500 feet. Flights 

that are below 1,500 ft. (457 m) and over the LBCHU between 1 July and 15 November will be reported 

to BOEM within 24 hr of the event.
Bird Strike Avoidance and Lighting Plan Chukchi Sea, Alaska

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4.0 REFERENCES

Day, R.H., A.K. Prichard, and J.R. Rose. 2005. Migration and collision avoidance of eiders and other 

birds at Northstar Island, Alaska, 2001-2004: Final Report. Prepared for BP Exploration 

(Alaska) Inc.; prepared by ABR, Inc. - Environmental Research & Services, Fairbanks, AK. 154 

pp.

d’Entremont, M.V., H.J. Reider and D. Funk. 2013. Shell Exploratory Drilling: 2012 Bird Strike and 

Avoidance Report. Unpublished report by LGL Alaska Research Associates, Anchorage, AK, for 

Shell Offshore Inc., Anchorage, AK. 33 pp.

Desholm, M. and J. Kahlert. 2005. Avian collision risk at an offshore wind farm. Biology Letters. 

1:296-298. http://www.journals.royalsoc.ac.uk/media/2g271rrhuj5twjvhhl5x/contributions/

n/7/8/y/n78yk3nl7j2k3rn3.pdf. Site accessed December 14, 2006.

Gall, A. and R. Day. 2009. Distribution and abundance of seabirds in the northeastern Chukchi Sea, 

2008. Final Report prepared for ConocoPhillips Alaska Inc., Anchorage, AK and Shell 

Exploration & Production Company, Anchorage, AK by ABR, Inc. – Environmental Research & 

Services, Fairbanks, AK. 55 pp.

Gall, A. and R. Day. 2010. Distribution and abundance of seabirds in the northeastern Chukchi Sea, 

2008-2009. Prepared for ConocoPhillips Alaska Inc., Anchorage, AK, Shell Exploration & 

Production Company, Anchorage, AK, and Statoil USA E&P, Inc., Anchorage, AK by ABR, Inc. 

– Environmental Research & Services, Fairbanks, AK. 68 pp.

Gall, A. and R. Day. 2012. Distribution and abundance of seabirds in the Northeastern Chukchi Sea 2008-

2011. Final Report. Anchorage, AK: ABR, Inc. pp 54. 

Gauthreaux, S.A. and C.G. Belser. 2005. Radar ornithology and the conservation of migratory birds. in: 

C.J. Ralph and T.D. Rich, editors. Bird Conservation Implementation and Integration in the 

Americas: Proceedings of the Third International Partners in Flight Conference. 2002 March 20-

24. pp. 871-875. Asilomar, California; Volume 2. Gen. Tech. Rep. PSW-GTR-191. Albany, 

CA: Pacific Southwest Research Station, Forest Service, U.S. Department of Agriculture.

Gauthreaux, S.A. and J.W. Livingston. 2006. Monitoring bird migration with a fixed-beam radar and 

thermal-imaging camera. Journal of Field Ornithology. 77:319-328.

Jones, J. and C.M. Francis. 2003. The effects of light characteristics on avian mortality at lighthouses. 

Journal of Avian Biology. 34:328–333.

Larkin, R. P., and Thompson, D. 1980. Flight speeds of birds observed with radar evidence for 2 phases 

of migratory flight. Behavioral Ecology and Sociobiology (7): 301-317.

LGL. 2010. Marine mammal and seabird monitoring during the 2010 COMIDA/Shell cruise, Chukchi 

and Beaufort seas. Anchorage, AK: LGL. pp 67.

Manville, A.M. 2005. Bird strikes and electrocutions at power lines, communication towers, and wind 

turbines: state of the art and state of the science – next steps toward mitigation. USDA Forest 

Service General Technical Report. PSW-GTR-191.

Marquenie, J.M. 2007. Green light to birds – investigation into the effect of bird-friendly lighting. 

Netherlands Aardolie Maatschappij. The Netherlands.
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MMS. 2003. Beaufort Sea planning area-Oil and Gas Lease Sales 186, 195, and 202. Final 

environmental impact statement. Vol. I. OCS EIS/EA MMS 2003-001. U.S. Department of the 

Interior, Minerals Management Service, Alaska OCS Region. Anchorage, AK.

MMS. 2006. Biological evaluation of Steller’s eider (Polysticta stelleri), spectacled eider (Somateria

fischeri), and Kittlitz’s murrelet (Brachyramphus brevirostris) for seismic surveys in the 

northeast Chukchi Sea and western Beaufort Sea planning areas. Alaska OCS Region. 

Anchorage, AK. March 2006. 

MMS. 2007a. Information to lessees, Oil and Gas Lease Sale 202, Beaufort Sea. April 18, 2007. 

MMS. 2007b. Chukchi Sea planning area-Oil and Gas Lease Sale 193 and seismic surveying activities in 

the Chukchi Sea. Final environmental impact statement. Vol. I-III. OCS EIS/EA MMS 2007-

026. Alaska OCS Region. Anchorage, AK. May 2007.

MMS. 2008a. Final lease stipulations Oil and Gas Lease Sale 193, Chukchi Sea February 6, 2008. U.S. 

Department of Interior, Minerals Management Service, Alaska OCS Region, Anchorage, AK. 12 

pp.

MMS. 2008. Final information to lessees Oil and Gas Lease Sale 193, Chukchi Sea. February 6, 2008.

New Mexico Department of Game & Fish. 2001. New Mexico Department of Game and Fish guidelines 

for mitigating bird mortality from communications towers. Conservation Services Division. 

http://www.wildlife.state.nm.us/conservation/habitat_handbook/documents/CommunicationTowe

rGuidelines.pdf.

Petersen, M.R., W.W. Larned, and D.C. Douglas. 1999. At-sea distributions of spectacled eiders: A 120 

year-old mystery resolved.” Auk. 116:1009-1020.

Richardson, W.J. and S.R. Johnson. 1981. Waterbird migration near the Yukon and Alaskan Coast of the 

Beaufort Sea. Arctic. 34:108-121.

Shell Gulf of Mexico Inc. 2011. Revised Chukchi Sea exploration plan OCS Lease Sale 193, Chukchi 

Sea, Alaska, exploration drilling program Posey Area Blocks 6714, 6762, 6764,6812, 6912, 

6915. Submitted to U.S. Department of Interior, Bureau of Ocean Energy Management, 

Regulation and Enforcement, Alaska OCS Region by Shell Gulf of Mexico Inc., Anchorage, AK.

(EP Revision 1)

Shell Gulf of Mexico Inc. 2013. Revised Chukchi Sea exploration plan OCS Lease Sale 193, Chukchi 

Sea, Alaska, exploration drilling program Posey Area Blocks 6714, 6762, 6764,6812, 6912, 

6915. Submitted to U.S. Department of Interior, Bureau of Ocean Energy Management, Alaska 

OCS Region by Shell Gulf of Mexico Inc., Anchorage, AK. (EP Revision 2)

Troy Ecological Research Associates. 1999. Spectacled Eiders in the Beaufort Sea: Distribution and 

Timing of Use. Final Report. BPXA. Anchorage, AK. 

USFWS. 1996. Spectacled eider recovery Plan. U.S. Fish and Wildlife Service. Anchorage, AK.
Bird Strike Avoidance and Lighting Plan Chukchi Sea, Alaska

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USFWS. 2003. Biological opinion for Minerals Management Service’s proposed Beaufort Sea Natural 

Gas and Oil Lease Sale 186. in: Beaufort Sea Planning Area Oil and Gas Lease Sales 186, 195, 

and 202 Final Environmental Impact Statement. MMS. Alaska OCS Region. Anchorage, AK. 

MMS 2003-001. Vol. 4.

USFWS. 2005a. ADVISORY: recommended time periods for avoiding vegetation clearing in Alaska in 

order to protect migratory birds. Anchorage, Alaska.

USFWS. 2005b. Alaska’s threatened and endangered species. Unpublished report. U. S. Fish and 

Wildlife Service, Anchorage Field Office, Anchorage, Alaska. March 2005.

USFWS. 2006a. ESA basics fact sheet. June 2006.

USFWS. 2006b. Threatened and endangered species: a consultation guide for south central Alaska. 

June 2006.

Verheijen, F.J. 1985. Photopollution: artificial light optic spatial control systems fail to cope with:

incidents, causations, remedies. Experimental Biology. 44:1-18.

Woodby, D.A. and G.J. Divoky. 1982. Spring migration of eiders and other waterbirds at Point Barrow, 

Alaska. Arctic. 35:403-410.
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Attachment A

Attachment A

Lease Stipulation No. 7

Oil and Gas Lease Sale 193 Chukchi Sea
Bird Strike Avoidance and Lighting Plan Chukchi Sea, Alaska

Shell Gulf of Mexico, Inc. A-1 March 2015

Bird Strike Avoidance and Lighting Plan 

Attachment A

LEASE STIPULATION NO. 7

OIL AND GAS LEASE SALE 193 CHUKCHI SEA

Stipulation No. 7. Measures to Minimize Effects to Spectacled and Steller’s Eiders During Exploration 

Activities. This stipulation will minimize the likelihood that spectacled and Steller’s eiders will strike 

drilling structures or vessels. The stipulation also provides additional protection to eiders within the 

blocks listed below and Federal waters landward of the sale area, including the Ledyard Bay Critical 

Habitat Area, during times when eiders are present.

(A) General conditions: The following conditions apply to all exploration activities.

(1) An EP must include a plan for recording and reporting bird strikes. All bird collisions (with 

vessels, aircraft, or drilling structures) shall be documented and reported within 3 days to MMS. 

Minimum information will include species, date/time, location, weather, identification of the vessel, 

and aircraft or drilling structure involved and its operational status when the strike occurred. Bird 

photographs are not required, but would be helpful in verifying species. Lessees are advised that the 

FWS does not recommend recovery or transport of dead or injured birds due to avian influenza 

concerns.

(2) The following conditions apply to operations conducted in support of exploratory and delineation 

drilling.

(a) Surface vessels (e.g., boats, barges) associated with exploration and delineation drilling 

operations should avoid operating within or traversing the listed blocks or Federal waters between 

the listed blocks and the coastline between April 15 and June 10, to the maximum extent 

practicable. If surface vessels must traverse this area during this period, the surface vessel 

operator will have ready access to wildlife hazing equipment (including at least three Breco buoys 

or similar devices) and personnel trained in its use; hazing equipment may located onboard the 

vessel or on a nearby oil spill response vessel, or in Point Lay or Wainwright. Lessees are 

required to provide information regarding their operations within the area upon request of MMS. 

The MMS may request information regarding number of vessels and their dates of operation 

within the area.

(b) Except for emergencies or human/navigation safety, surface vessels associated with 

exploration and delineation drilling operations will avoid travel within the Ledyard Bay Critical 

Habitat Area between July 1 and November 15. Vessel travel within the Ledyard Bay Critical 

Habitat Area for emergencies or human/navigation safety shall be reported within 24 hr to MMS.

(c) Aircraft supporting drilling operations will avoid operating below 1,500 feet above sea level 

over the listed blocks or Federal waters between the listed blocks and the coastline between April 

15 and June 10, or the Ledyard Bay Critical Habitat Area between July 1 and November 15, to 

the maximum extent practicable. If weather prevents attaining this altitude, aircraft will use predesignated flight routes. Predesignated flight routes will be established by the lessee and MMS, 

in collaboration with the FWS, during review of the EP. Route or altitude deviations for 

emergencies or human safety shall be reported within 24 hr to MMS.
Bird Strike Avoidance and Lighting Plan Chukchi Sea, Alaska

Shell Gulf of Mexico, Inc. A-2 March 2015

Bird Strike Avoidance and Lighting Plan 

Attachment A

(B) Lighting Protocols. The following lighting requirements apply to activities conducted between April 

15 and November 15 of each year.

(1) Drilling Structures: Lessees must adhere to lighting requirements for all exploration or 

delineation drilling structures so as to minimize the likelihood that migrating marine and coastal birds 

will strike these structures. Lessees are required to implement lighting requirements aimed at 

minimizing the radiation of light outward from exploration or delineation drilling structures to 

minimize the likelihood that birds will strike those structures. These requirements establish a 

coordinated process for a performance-based objective rather than pre-determined prescriptive 

requirements. The performance-based objective is to minimize the radiation of light outward from 

exploration/delineation structures while operating on a lease or if staged within nearshore Federal 

waters pending lease deployment.

Measures to be considered include but need not be limited to the following: 

 Shading and/or light fixture placement to direct light inward and downward to living and 

work structures while minimizing light radiating upward and outward;

 Types of lights;

 Adjustment of the number and intensity of lights as needed during specific activities;

 Dark paint colors for selected surfaces;

 Low-reflecting finishes or coverings for selected surfaces; and

 Facility or equipment configuration.

Lessees are encouraged to consider other technical, operational, and management approaches that 

could be applied to their specific facilities and operations to reduce outward light radiation. Lessees 

must provide MMS with a written statement of measures that will be or have been taken to meet the 

lighting objective, and must submit this information with an EP when it is submitted for regulatory 

review and approval pursuant to 30 CFR 250.203.

(2) Support Vessels: Surface support vessels will minimize the use of high-intensity work lights, 

especially when traversing the listed blocks and federal waters between the listed blocks and the 

coastline. Exterior lights will be used only as necessary to illuminate active, on-deck work areas 

during periods of darkness or inclement weather (such as rain or fog), otherwise they will be turned 

off. Interior lights and lights used during navigation could remain on for safety.

For the purpose of this stipulation, the listed blocks are as follows:
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Shell Gulf of Mexico, Inc. A-3 March 2015

Bird Strike Avoidance and Lighting Plan 

Attachment A

STIPULATION NO. 7

OIL AND GAS LEASE SALE 193, CHUKCHI SEA

LISTED BLOCKS 

NR02-06, Chukchi Sea:

6624, 6625, 6674, 6675, 6723-6725, 6773-6775, 6822, 6823, 6872

NR03-02, Posey:

6872, 6873, 6918-6923, 6967-6973, 7016-7023, 7063-7073, 7112-7123

NR03-03, Colbert

6674, 6723, 6724, 6771-6774, 6820-6824, 6869-6874, 6918-6924, 6966-6974,

7015-7024, 7064-7074, 7113-7124

NR03-04, Solivik Island

6011-6023, 6060-6073, 6109-6122, 6157-6171, 6206-6219, 6255-6268, 6305-6317,

6354-6365, 6403-6414, 6453-6462, 6502-6511, 6552-6560, 6601-6609, 6651-6658,

6701-6707, 6751-6756, 6801-6805, 6851-6854, 6901-6903, 6951, 6952, 7001

NR03-05, Point Lay West

6014-6024, 6062-6073, 6111-6122, 6160-6171, 6209-6221, 6258-6269, 6307-6317,

6356-6365, 6406-6414, 6455-6462, 6503-6510, 6552-6558, 6602-6606, 6652-6655,

6702, 6703

NR04-01, Hanna Shoal

6223, 6267-6273, 6315-6323, 6363-6373, 6411-6423, 6459-6473, 6507-6523,

6556-6573, 6605-6623, 6654-6671, 6703-6721, 6752-6771, 6801-6819, 6851-6868,

6901-6916, 6951-6964, 7001-7010, 7051-7059, 7101-7107

NR04-02, Barrow

6003-6022, 6052-6068, 6102-6118, 6151-6164, 6201-6214, 6251-6262, 6301-6312,

6351-6359, 6401-6409, 6451-6456, 6501-6506, 6551, 6552, 6601, 6602

NR04-03, Wainwright

6002-6006, 6052, 6053

NS04-08, (Unnamed)

6816-6822, 6861-6872, 6910-6922, 6958-6972, 7007-7022, 7055-7072, 7104-7122
Bird Strike Avoidance and Lighting Plan Chukchi Sea, Alaska

Shell Gulf of Mexico, Inc. March 2015

Bird Strike Avoidance and Lighting Plan 

Attachment B

Attachment B

Avian Collision Form
Bird Strike Avoidance and Lighting Plan Chukchi Sea, Alaska

Shell Gulf of Mexico, Inc. A-1 March 2015

Bird Strike Avoidance and Lighting Plan 

Attachment B 

AVIAN COLLISION FORM