In Reply Refer To: FO-2-1 January 5, 19*9

Cliffs Oil and QAS Coapany Attention! Mr. C. W. Ueavor 300 Citicorp Canter Bonaton, Texas 77002

Gentletoenr

P.eferenee ia nade to your Initial Development Operatione Coordination Document (DOCD) and accompanying information received December 29, 1988v

ft* Laane OC:,-C 770Qf Block 9*, South /Jarah Island Area. This DOCD includea tho activities proposed for Joll B-4.

In accordance with 30 CFR 250.3*, thia DOCD le hereby dcened submitted and la now beinr considered for approval.

lour control nuabar i« H-?1Q7 and should be referenced in your connuni-eaticn anu correspondence concerning this DOCD.

.Sincerely your a,

(Orig. Sgd.) A. Donald Giroir

3-D. J . Bourgeois Regional Superviaor Field Operations

MJTolbert:cck:12/30/88rdoedcon

Office of ram Services

JAN U 9 i 9 8 3

'"formation Services Section

O I L A N O G A S C O M P A N Y 300 CITICORP CENTER H O U S T O N TEXAS 77002 (713) OSl -9426

Cecember 22, 1988

Mr. Daniel J. Bourgeois ^»—-il^— Regional Supervisor Office of Field Operations U. S. Department of the Interior Minerals Manaqement Service 1201 Elmwood Park Boulevard New Orleans, Louisiana 70123-2394

RE: Development Operations Coordination Document OCS-G 7709, South Marsh Area Block 94 Offshore, Louisiana

Gentlemen:

In accordance with the provisions of T i t l e 30 CFR 250.34, C l i f f s Oil and Gas Company hereby submits for your review and approval nine (9) copies of a Development Operations Coordination Document (DOCD) for Lease OCS-G 7709, South Marsh Area Block 94, Offshore, Louisiana. Five (5) copies are "Propr ietary Information" and four (4) copies are "Public Information".

Excluded from the Public Information copies are certain geologic discussions, depth of wells and structure map.

In accordance with the associated Ac t i v i t y Schedule, C l i f f s Oil and Gas Company anticipates commencing a c t i v i t i e s under th is proposed Development Operations Coordination Document on February 1, 1989.

Should addit ional information be required, please contact our Regulatory Consultant, Ms. Jodie Connor, J . Connor Consulting at (713) 5580607.

Sincerely,

C. W. Weaver General Manager

CWW:JAC:bna Enclosures

cesmdcd

ii

CLIFFS OIL ANO GAS COMPANY

DEVELOPMENT OPERATIONS COORDINATION DOCUMENT

SOUTH MARSH AREA BLOCK 94

OCS-G 7709

Cliffs Oil and Gas Company (Cliffs), as designated Operator of the subject lease, submits this proposed Development Operations Coordination Document (DOCD) in accordance with the regulations contained in Title 30 CFR 250.34.

DESCRIPTION OF DEVELOPMENT ACTIVITIES

Under the Initial Plan of Exploration, Cliffs is presently drilling Well No. B-4 from existing Platform "B" in South Marsh Island 79.

Under this DOCD, Cliffs proposes to produce one well (B-4) from existing Platform "BH in South Marsh Island 79.

Activities proposed under this DOCD for South Marsh Area Block 94 will commence February 1, 1989 with the start up of production.

Activity Approximate start-up Date

1. Commence Production February 1, 1989

DESCRIPTION OF PLATFORM

A plat showing the surface location of existinq Production Platform "B" in South Marsh Island 79 is enclosed as Attachment A. Platform "B" is a 4-pile, production platform.

All hydrocarbon handling equipment for testing and production such as separators, tanks, and treaters were designed, installed, and operated to prevent pollution.

Maintenance or repairs which are necessary to prevent pollution of offshore waters shall be undertaken immediately.

Curbs, gutters, drip pans, and drains are installed in deck areas in a manner necessary to collect all contaminants not authorized for discharge. Oil drainage is piped to a properly designed, operated, and maintained sump system which will automatically maintain the oil at a level sufficient to prevent discharge of oil into offshore waters. All gravity drains are equipped with a water trap or other means to prevent gas in the sump system

from escaping through the drains. Sump piles are not used as processing devices to treat or skim liquids, but may be used to collect treated-produued water, treated-produced sand, or liquids from drip pans and deck drains and as a final trap for hydrocarbon liquids In the event of equipment upsets. Improperly designed, operated, or maintained sump piles which do not prevent th" discharge of oil into offshore waters shall be replaced or repaired.

There shall be no disposal of equipment, cables, chains, containers, or other materials into offshore waters.

WELL LOCATION

A table Indicating the surface location, bottom hole location, total vertical depth and measured otpth for the well covered by this DOCO is enclosed as Attachment B.

STRUCTURE MAP

A current structure map of the expected productive formations showing the surface and bottom hole location of the proposed well 1s enclosed as Attachment C.

BATHYMETRY MAP

The existing surface location as shown on the Bathymetry Map was Included with the Initial Plan of Exploration.

SHALLOW HAZARDS

Information on geological hazards and surface locations relative to anomalies was included in the Initial Plan of Exploration submitted for South Marsh Island Block 79.

OIL SPILL CONTINGENCY PLAN

All production operations shall be performed in accordance with Industry standards to prevent pollution of the environment. Cliffs' Oil Spill Contingency Plan has been approved by the MMS. This plan designates an Oil Spill Team consisting of Cliffs personnel and contract personnel. This team's duties are to eliminate the source of any spill, remove all sources of possible Ignition, deploy the most reliable means of available transportation to monitor the movement of a slick, and contain and remove the slick if possible.

Cliffs 1s a member of Clean Gulf Associates (CGA). The CGA has two pennanent equipment bases in Texas, at Rockport and Galveston, and four bases in Louisiana, at Venice, Grand Isle, Intracoastal City and Cameron. Each base 1s equipped with fast response skimmers and there is a barge mounted high volume open sea skimmer based at Grand Isle, Louisiana. In addition to providing equipment, the CGA also supplies advisors for clean-up operations. Equipment available from CGA and the base i t is located at is listed in the CGA Manual, Volume I , Section I I I .

Estimated response time for a spill In South Marsh Island 79 could vary from 8 to 10 hours. Equipment located in Intracoastal City, Louisiana would be utilized f i r s t with additional equipment transported from the nearest equipment base on-site as required.

In the event a spill occurs from South Marsh Island 94, our company has projected trajectory of a spill utilizing information In the Environmental Impact Statement (EIS) for OCS Lease Sales 118 and 122.

The EIS contains cil spill trajectory simulations using seasonal surface currents coupled with wind data, adjusted every 3 hours for 30 days or until a target is contacted.

Hypothetical spill trajectories were simulated for each of the potential launch sites across the entire Gulf. These simulations presume 500 spills occurring in each of the four seasons of the year. The results in the EIS were presented as probabilities that an oil spill beginning from a particular launch site would contact a certain land seqment within 3, 10, or 30 days. Utilizing the summary of the trajectory analysis (for 10 days) as presented on pages IV-40 through IV-45, the probable projected land fal l of an oil spill is as follows. Also listed is the CGA Map Number corresponding to the land segment which will be utilized to determine environmentally sensitive areas that may be affected by a spill.

AREA LANO SEGMENT CONTACT PERCENT CGA MAP NUMBER

South Marsh Island 79 Jefferson County, TX 1% TX Map No. 4 & Cameron Parish, LA LA Map No. 5

Vermilion Parish, LA 8% LA Map No. 5

Iberia Parish, LA 4% LA Map No. 6 St. Mary Parish, LA

West St. Mary Parish, LA 3% LA Map No. 6

Terrebonne Parish, .A 7% A Map No. 6

Section V, Volume I I of the CHA Manual containing maps as listed above, also includes containment/cleanup protection response modes for the sensitive areas.

Section VI, Volume I I of the CGA Operations Manual depicts the protection response modes that are applicable for oil spill clean-up operations. Each response mode is schematically represented to show optimum deployment and

operation of the equipment 1n areas of environmental concern. Implementation

ion

NEW OR UNUSUAL TECHNOLOGY

No new techniques or unusual technology will be required for this operation.

LEASE STIPULATIONS Lease Stipulation No. 1 1s attached to both leases Block 79 and Block 94. A Cultural Resources Report assessing the potential existence of any cultural resource for the surface location in Block 79 was submitted with the Initial Plan of Exploration. This plan does not propose any surface locations in Block 94.

DISCHARGES

All discharges rom Production Platform "B" will comply with the Environ­mental Protection Agency NPDES General Permit for the Gulf of Mexico.

The permittee 1s authorized by the General Permit to discharge the effluents listed in the following table. Such discharges will be limited and monitored by the permittee as specified below:

Discharge and Effluent Character!stic

Monitoring Requirements Discharge Measurement Sample Recorded Limitation Frequency Typg/Method Value(s)

DECK DRAINAGE

Free Oil

Vol ume(barrels)

PRODUCED WATER

No Free Oil Once/day 1/

Once/month

Oil and Grease 72 mg/1 Once/month daily max. 48 mg/1

:h

Visual/Sheen on receiving water

Estimate

Grab 3/

monthly avg.

Flow (MGD) Once/month Estimate

Number of Days Sheer Observed

Month Total 2/

Daily Maximum & Monthly Avg.

Monthly Avg.

PRODUCED SAND

Free Oil

Weight (lbs)

No Free Oil Once/day 4/

Once/month

Visual/Sheen on receiving water

Estimate

Number of Days Shee observed

Mtnly Total 2/

WELL TREATMENT FLUIDS/ COMPLETION FLUIDS5/ WORKOVER FLUIDS5/

Free Oil No Free Oil 0nce/day4/ Visual/Sheen cn receiving water

Volume (barrels) Once/month Estimate

SANITARY WASTE6/ (continuously manned by 10 or more persons)

Residual Chlorine7/ 1 mg/1 Once/month Grab

Flow (MGD) Once/month Estimate

Number of Days Sheen observed

Mnthly Total2/

Concentration

Mnthly Avg.2/

SANITARY WASTE (continuously manned by 9 or fewer persons or Intermittently by any number)

Sol ids

DOMESTIC WASTE

Solids

No Floating Once/day Solids

No Floating Once/day Solids

Observations/ Number of Days Solids Observed

Observations/ Number of Days Solids Observed

DESALINIZATION UNIT DISCHARGE; BLOWOUT PREVENTER FLUID; UNCONTAMINATED BALLAST WATER; UNCONTAMINATED BILGE WATER; MUD, CUTTINGS AND CEMENT AT THE SEAFLOOR; UNCONTAMINATEU SEAWATER; BOILER BLOWDOWN; SOURCE WATER AND SAND

Free Oil No Free Oil 0nce/day4/ Visual/Sheen Number of Days on receiving Sheen Observed water surface

1/ When discharging and tacility is manned. Monitoring shall be accomplished durinq daylight by visual observation of the receiving water surface in the vicinity of tne discharge.

2/ This infomation shall be recorded, but not reported unless otherwise requested by EPA.

3/ May be based on the arithmetic average of four grab sample results in the twenty-four hour period. The Regional Administrator may approve an a l te rna t ive test method on a case-by-case basis.

4 / When discharging. Monitoring shall be accomplished during daylight by v isual observation of the receiving water surface 1n the v i c in i t y of the discharge.

5/ No discharge of p r i o r i t y pol lutants except in trace amounts. Information on the specif ic chemical composition shall be recorded, but not reported unless requested by EPA.

6/ Any f a c i l i t y which properly operates and maintains a marine sanitation device (MSO) that compiles with po l lu t ion control standards and regulat ions under Section 312 of the Act shall be deemed to be in compliance with permit l imi ta t ions for sanitary waste. The MSO shall be tested yearly for proper operation and test results maintained at the f a c i l i t y .

TJ Hach method CN-66-DP0 approved. Minimum of 1 mg/1 and maintained as close to th i s concentration as possible.

8/ Monitoring shall be accomplished during daylight by visual observation of the surface cf the receiving water in the v i c in i t y of sanitary and domestic waste o u t f a l l s . Observations shall be mai e following either tfie morning or mid-day meals and at a time during daylight and maximum estimated discharge.

Discharges w i l l be free of o i l and w i l l be in compliance with and monitored as required by EPA NPDES General Permit {GMG 280000) in accordance with 40 C.'R 122-6. Any o i l contaminated mud w i l l be transported to shore for proper d isposal .

HYDROGEN SULFIDE

This area is not known to contain H2S.

COASTAL ZONE CONSISTENCY

A C e r t i f i c a t e of Coastal Zone Consistency as required by T i t l e 15 CFR Part 930 is included as Attachment D.

PROJECTED EMISSIONS

No d r i l l i n g ac t i v i t i es are proposed under th is DOCD. One well is being produced through ex is t ing f a c i l i t i e s , therefore a i r qual i ty w i l l not be af fected by these operations. No a i r qual i ty review is being submitted with th is DOCD.

ENVIRONMENTAL REPORT

An Environmental Report is included as Attachment E

ONSHORE BASE

South Marsh Island Area Block 79/94 is located approximately 88 miles from shore, in a water depth of approximately 135 feet. A map snowing the location of Blocks 79/94 relative to the shoreline and onshore base is included as Attachment F.

Cliffs will utilize existing onshore facilities located in Intracoastal City, Louisiana. This will serve as port of debarkation for supplies and crews.

No onshore expansion or construction is anticipated with respect to this activity.

This base is capable of providing the services necessary for the proposed activities. It has 24 hour service, a radio tower with a phone patch, dock space, equipment and supply storage base, drinking and d r i l l water, etc. During production activities one supply boat will be making 1 trip per week and one helicopter will make 4 trips per week.

The onshore activities associated with South Marsh Island Blocks 79/94 should not result in any Increase in the size and number of onshore support and storage facilities or land and personnel requirements.

AUTHORIZED REPRESENTATIVE

Inquiries may be made to the following authorized representative of Cliffs Oil and Gas Company:

Jodie Connor Regulatory Agent J. Connor Consulting 11767 Katy Freeway, Suite 812 Houston, Texas 77*079 (713) 558-0607

LIST OF ATTACHMENTS

A Platform Location Plat B Location of Well C Structure Map 0 Coastal Zone Consistency Cer t i f i ca t ion E Environmental Report F V i c i n i t y Map

i I 1 , 8 2 4 , 4 7 8 762 Y • W 3 4 . 2 3 2 9 6 3 BLK. 78 x = 1 ,833 ,063 0 4

Y » ( - ) 3 4 , 2 5 2 9 6 3

i BLK. 80

BLOCK 79 0 C 3 - G 7704

X-1,824,476 762 Y M - ) 4 9 , 0 M 013

2174

PHOPOSFO PLATFORM " B " Cl<ff» Exploration Company Block 7 9 X = 1,826,652 76 Y 1 (-) 4 4 , 4 9 6 01 LAT i 2 8 ° 3 2 ' 3 5 50" LONG • 9 I ° 3 2 ' 2 3 l l "

BLK 94

MOTE Coordinate* thown ar t bOMd on ttM Loutuana Ptort* Coordmot* Sy*t*<r, South

/ ttorooy osrfify thot this u a truo ond corroct p

JOA* T Jo*y***

jm*m r Amm** O **

tt.A.S km 4391 sr*****.

BLK 244

BLK 24 5

x i 1,833,063 0 4 Y M - ) 4 9 , 0 l l 013

C L I F F S EXPLORATION CO.

PLATFORM V BLOCK 79

SOUTH MARSH I S L A N D SOUTH ADDITION

M M . %-\*-%% [ iCAcI- l' » SOOO *—• • oa • > m

f ^

ATfACHHLN

ATTACHMENT "B-

WELL NO. LOCATIONS

1 SL: 4515' FSL / 2174' FWL of Blocic 79

TOTAL DEPTH WATER DEPTH

13352 MO 135'

COASTAL ZONE MANAGEMENT

CONSISTENCY CERTIFICATION

DEVELOPMENT OPERATIONS COORDINATION DOCUMENT

SOUTH MARSH ISLAND AREA BLOCK 94 - OCS-G-7709

The proposed a c t i v i t i e s described in detail In this Plan comply with Louisiana's approved Coastal Zone Management Program and w i l l be conducted in a manner consistent with such Program.

Gas Company Tessee or Operator

C.H. Jrieflvgr, , • .,, , -Cerf i fying Offi ci aT

December 28, 1988 Uate

ENVIRONMENTAL REPORT

FEDERAL LEASE OCS-G 7709

SOUTH MARSH ISLAND AREA BLOCK 94

OFFSHORE, LOUISIANA

THE FOLLOWING ENVIRONMENTAL REPORT WAS PREPARED BY J. CONNOR CONSULTING FOR CLIFFS OIL AND GAS COMPANY FOR COASTAL ZONE CONSISTENCY DETERMINATION BY THE STATE OF LOUISIANA ON OPERATIONS PROPOSED TO BE CONDUCTED IN THE DEVELOPMENT OPERATIONS COORDINATION DOCUMENT FOR LEASE OCS-G 7709. FOR INQUIRIES REGARDING THIS REPORT PLEASE CONTACT:

CLIFFS OIL AND GAS COMPAN.

1200 SMITH, SUITE 300

HOUSTPN, TEXAS 77002

ATTENTION: MR. C. W. WEAVER

DECEMBER, 1988

i

ATTACHMENT E

TABLE OF CONTENTS

TITLE PAGE 1

TABLE OF CONTENTS 11

I . DESCRIPTION OF PROPOSED ACTION 1

A. DESCRIPTION OF PROPOSED TRAVEL MOOES, ROUTES AND 1 FREQUENCY

B. ONSHORE SUPPORT SYSTEMS 1 C. NEW OR UNUSUAL TECHNOLOGY 1 D. VICINITY MAP 1 E. PROPOSED MEANS TO TRANSPORT OiL AND GAS TO SHORE 2

ROUTES, QUANTITIES

I I . DESCRIPTION OF AFFECTED ENVIRONMENT 2

A. COMMERCIAL FISHING 2 B. SHIPPING 3 C. PLEASURE BOATING, SPORT FISHING AND RECREATION 3 D. POTENTIAL OR KNOWN CULTURAL RESOURCES 4 E. ECOLOGICALLY SENSITIVE FEATURES 5 F. PIPELINES AND CABLES 5 S. OTHER MINERAL USES 6 H. OCEAN DUMPING 6 I . ENDANGERED OR THREATENED SPECIES AND CRITICAL 6

HABITAT

I I I . UNAVOIDABLE ADVERSE ENVIRONMENTAL EFFECTS 7

A. WATER QUALITY 7 B. EFFECTS ON MARINE ORGANISMS 7 C. WETLANDS AND BEACH 7 D. AIR QUALITY 7 E. COMMERCIAL FISHING 7 F. SHIP NAVIGATION 8 G. CULTURAL RESOURCES 8 H. RECREATION AND AESTHETIC VALUES 8

IV. SUMMARY 9

REFERENCES 10

11-

I. DESCRIPTION OF PROPOSED ACTION

Cliffs 011 and Gas Company plans to conduct development activities on South Marsh Island Area Block 94, OCS-G 7709.

As proposed, the Development Operations Coordination Document for South Marsh Island Area Block 94 inlcudes producing one (1) well from existing Production Platform "B" located 1n South Marsh Island 79.

At this time, planned commencement date for production activities 1s on or about February 1, 1989.

A. DESCRIPTION OF PROPOSED TRAVEL MOOES, ROUTES AND FREQUENCY

A supply boat will be dispatched from a support base located in Intracoastal City, Louisiana. The boat will normally move to the block via the most direct route from Intracoastal City, Louisiana, however, boats operating in the field m-y travel from other facilities nearby. Following is an estimate of trips to the proposed operation.

B. ONSHORE SUPPORT BASE

The proposed activities will utilize a support base located at Intracoastal City, Louisiana. This base provides 24-hour service, a radio tower with phone patch, dock space, office space, parking lot, equipment and supply storage space, drinking and drill water, etc. The proposed development activities will help to maintain this base at its present level of activity. No expansion of the physical facilities or the creation of new jobs is expected to result from the work planned in conjunction with this block.

C. NEW OR UNUSUAL TECHNOLOGY

No new techniques or unusual technology will be required for these operations.

Supply Boat Helicopter

Production Operations

1 trip per week 4 trips per week

D. VICINITY MAP

South Marsh Island Area Block 94 is located approximately 88 miles south of Intracoastal City, Louisiana. Water depth is approximately 135'. See Attachment A.

E. PROPOSED MEANS TO TRANSPORT OIL AND GAS TO SHORE, ROUTES, QUANTITIES

Hydrocarbons will be transported via an existing pipeline in South Marsh Island Blocic 79 Platform "B" to a sub-sea tle-ln In South Marsh Island Block 77.

II. DESCRIPTION OF AFFECTED ENVIRONMENT

A. COMMERCIAL FISHING

The Gulf of Mexico is the single most important area for fisheries production In the United States. In 1985, the total landings of all fisheries in the Gulf was about 2.4 billion pounds, valued at $596 million dockside, and represented about 38% of the total United States landings by pounds and 26% by value. In 1985, the top four U.S. ports in quantity of commercial fishery landings were Cameron, Louisiana; Pascagoula-Moss Point, Mississippi; and Dulac-Chauvin and Empire-Venice, Louis1'..na.

The Gulf shrimp fishery represents the single most valuable fishery in the United States with landings (heads removed; averaging approximately 230 million lbs/yr. The major shrimp species include brown, white, and pink shrimp. In 1981 production reached almost 270 million pounds worth over $401 million dockside. In addition to shrimp, the blue crab significantly contributes to the Gulf's crustacean landings. In 1985, about 56 million pounds of blue crabs, worth about $16 million, were taken in the Gulf's near-shore estuaries and sound. Oysters are the main mollusk harvested in the Gulf's nearshore estuaries id sounds, and oyster landings in 1985 were approximately 26.5 mil1 on pounds valued at about $41 million.

In the Gulf the following commercial fishes were the most economically important in 1985 and ara arranged in order of decreasing priority: gulf menhaden, groupers and scamp, red snapper, black mullet, red drum, yellowfin tuna, catfish and bullheads, swordfish, black drum, spotted seatrout, yellow-tail snapper, pompano, vermilion snapper, and king mackerel and cero.

The menhaden purse seino fishery is the most important fishery in terms of pounds landed. In 1985, 1.9 billion pounds valued at $67 million were landed in the Gulf. Menhaden are used In the manufacture of fish meal and solubles for additives to livestock feeds, and production of fish oil. Also, small amounts are used for bait and canned pet food.

The industrial bottomfish trawl fisnery produces stock fcr the pet food industry, bait, animal food, and fishmeal. This fishery reached peak production in the early 1970's at about 115 millions pounds, worth about $2.8 million; however, it has declined in recent years.

Shrimp is by far the most valuable component of the Louisiana landings. The menhaden fishery Is the largest 1n terms of pounds landed. In 1985, the total commerc: i landings for Louisiana were about 1.7 billion pounds, worth $229 million. Louisiana ranked first in the United States in pounds landed and second in value.

B. SHIPPING

Fairways play an important role in the avoidance of collisions on the OCS, particularly In the case of the large oceangoing vessels, but not all vessels stay within the fairways. Many others, such as fishing boats and OCS support vessels, travel througn areas with high concentrations of fixed structures. In such cases the most important mitigation factor is the requirement for adequate marking and lighting of structures. After a structure has been 1n place for a while, it often Becomes a landmark and an aid to navigation for vessels that operate in the area on a regular basis.

South Marsh Island Block 79 is clear of all shipping fairways and anchorage areas. The platform and each of the marine vessels servicing this operation will be equipped with all U. S. Coast Guard required navigational safety aids.

C. PLEASURE BOATING, SPORT FISHING AND RECREATION

The northern Gulf of Mexico coastal zone is one of the major recreational regions of the United States, particularly in connection with marine fishing and beach-related activities. The shorefronts along the Gulf coasts of Alabama, Mississippi, Louisiana, and Texas offer a diversity of natural and developed landscapes and seascapes. The coastal beaches, barrier islands, estuarine bays and sounds, river deltas, and tidal marshes are extensively and intensively utilized for recreational activity bv residents of the Culf South and tourists from throughout the Nation, as well as from foreign countries. Publicly-owned and administered areas such as National seashores, parks, beaches, and wildlife lands, as well as specially designated preserv­ation areas such as historic and natural sites and landmarks, wilderness areas, wildlife sanctuaries, and scenic rivers attract residents and visitors throughout the year. Commercial and private recreational facilities and QS cabl ishments, such as resorts, marinas, amusement parks, and ornamental gardens, also serve as primary interest areas and support services for people who seek enjoyment from the recreational resources associated with the Gulf.

The two major recreational areas most directly associated with offshore leasing and potentially affected by it are the offshore marine environment and the coastal shorefront of the adjoining states. The only major recreational activity occurring on the OCS is offshore marine recreational fishing and diving. Studies, reports, and conference proceedings published Dy MMS and others have documented a substantial recreational fishery. Including scuba diving, directly associated with oil and gas production platforms. The recreational fishing associated with oil and gas structures stems from their function as high profile artificial fishing reefs. A report on the 1984 Marine Recreational Fishery Statistics Surveys presented by NMFS at the Sixth Annual Gulf of Mexico Information Transfer Meeting indicates a majority of the offshore recreational fishing in the Central Gulf of Mexico 1s directly associated with oil and gas structures. There are currently about 4,000 offshore oil and gas structures in the Central and Western Gulf of Mexico. Many other studies have demonstrated that when oil and gas structures are accessible to marine recreational fishermen ind scuba divers they are a major attraction for marine recreational activities and are a positive Influence on tourism and coastal economics.

3

With the exception of Grand Isle and vicinity and a stretch of beach area in Cameron Parish, (Peveto/Constance/Ocean View Beaches, Holly Beach, Hackberry Beach) Louisiana has very limited beach area suitable for recreation. Most of i t is very narrow, of poor recreational quality and generally inaccessible by automobile, some of the highest quality beach areas in coastal Louisiana are found along the barrier islands chain off Terrebonne Parish. Several additional significant recreational resources are found along the Gulf Coast. Louisiana has ornamental gardens, scenic roads, rivers, and trails.

D. POTENTIAL OR KNOWN CULTURAL RESOURCES

Archaeological resources are any objects or features which are man-made or modified by human activity. Significant archaeological resources are either historic or prehistoric and, as defined by 30 CFR b0.6, generally include properties greater than 50 years old which are associated with events that have made a significant contribution to the broad patterns of our history; are associated with tiie lives of persons significant in the past; embody the distinctive characteristics of a type, period, or method of construction; represent the work of a master; possess high artistic values; represent a significant and distinguishable entity whose components may lack individual distinction; or have yielded, or may be likely to yield, information important in prehistory or history.

Although most historic archaeological resources on the OCS are shipwrecks, other types of historic sites, such as the Ship Shoal Lighthouse, may occur in Federal waters.

Figures indicate that less than 2% of pre-20th century ships reported in the Guif and less than 10% of all ships reported lost between 1500 and 1945 have known locations. Considering the problems with inaccurate wreck reporting, d r i f t and breakup of wrecks, and ships which have been lost but never reported, i t becomes apparent that very l i t t l e is really known about the locations of historic shipwrecks in the Gulf of Mexico.

In order to deal with the management problems of this largely unlocated resource base, a high probability zone for the occurrence of shipwrecks (Zone 1) was proposed by the baseline study (CEI, 1977). This zone was delineated by using geographic factors, such as approaches to seaports, straits, shoals, reefs, and historic shipping routes, as indicates of high shipwreck potential.

Required remote sensing surveys on the OCS have recorded evidence of approximately 57 potential wrecks. Ten of these are definite wrecks while the remaining 47 would require further investigation for positive identi­fication. Eighty percent of these possible wrecks were recorded within Zone 1 which, according to the baseline study, is where the highest incidence of shipwrecks should occur.

E. ECOLOGICALLY SENSITIVE FEATURES

Barrier beaches are a common landform along the Gulf Coast and stretch in an irregular chain from Florida to Texas. These elongated, narrow landforms are composed of sand and other loose sediments transported by waves, currents, storm surges, and wind. In geological terms, barrier islands are a young phenomenon, being formed only in the last 5000 to 6000 years. The term "barrier" identifies the structure as one that protects other features, such as bays, estuaries, and marshes, from direct wave attack of the open ocean. The waters in these bays and estuaries are a blend of the terrestrial-freshwater systems of the mainland and the saltwater system of the ocean, and among the richest ecosystems known. Many of the species that inhabit the bays, estuaries, and adjacent marshes use these areas as spawning, nursery, and feed grounds.

Another benefit of both the islands and their adjacent marshes and bays is that of providing habitats fur a large number of birds and other animals. The islands al o provide habitat for several threatened or endangered species, for example, the loggerhead turtle, the southern bald eagle, alliga­tors, and brown pelicans.

The shelf and shelf edge of the Central and Western Gulf are characterized by topographic features which are inhabited by benthic communities. The benthic organisms on these features appear to be depth related; however, the actual limiting factors are temperature and light penetration (turbidity and sedimentation).

The Central Gulf of Mexico lists 16 topographic features.

Shelf Edge Banks Midshelf Banks

Bright Bank Sonnier Bank McGrail Bank 29 Fathom Bank Rankin Bank Fishnet Bank Alderdice Bank Rezak Bank Sidner Bank Ewing Bank Jakkula Bank Bouma Bank Parker Bank Sackett Bank Diaphus Bank Sweet Bank

F. PIPELINES ANO CABLES

Any pipel ines crossing Block 79 are described in detai l in the Shallow Hazard Analysis previously submitted for th is block.

C l i f f s as a prudent operator w i l l avoid a l l pipelines and cables In th is block during development ac t i v i t i e s .

-5-

G. OTHER MINERAL USES

The activities proposed for South Marsh Island 94 will have no direct or indirect imoact on other mineral uses.

H. OCEAN DUMPING

Ocean dumping is prohibited in this area.

I . ENDANGERED OR THREATENED SPECIES AND CRITICAL HABITAT

Five federally listed endangered whale species occur within the Central Gulf. These include fin, humpback, right, sei, and sperm whales. Generally, these large cetaceans inhabit the continental slope and deep oceanic waters, occasionally they are sighted nearshore (Schmidly, 1981). Sperm whales have been sighted near the Louisiana Delta and offshore 8rownsville (Fritts et al., 1983).

Four federally listed endangered turtle species (Kemp's ridiey, green, hawksbill, and leatherback turtles) an'l one threatened species (loggerhead turtle) occur in the Gulf of Mexico.

The American alligator occurs generally throughout the Central Gulf coastal areas. The alligator is listed as endangered throughout its range except in the coastal areas of Florida and Texas where i t is listed as threatened and in Louisiana where i t is listed as "threatened by similarity of appearance".

The red-cockaded woodpecker occurs primarily in mature open pine forest throughout the Eastern and Central Gulf area and into eastern Texas.

Arctic peregrine falcons migrate along the eastern coast of Florida, the Florida Keys, and the Gulf coast of Texas. Some peregrine falcons overwinter along the Gulf coastal areas.

The northward migration corridor of the endangered eskimo curlew crosses the Louisiana and Texas coastal areas.

Brown pelicans occur along the coast of Cameron Parish, Louisiana. Bald eagles inhabit severrl Gulf coastal counties.

These species may be affected by the development of coastal lands and/or the occurrence of oil spills which may affect the species directly or through their food sources. Since the proposed activities include no plans for the development of the coastal lands, the impact on endangered or threatened species is primarily based on the occurrence of oil spills.

Cliffs as a prudent operator, will take the necessary measures to reduce the probability of oil spills. Cliffs' prooosed development operations on Block 94 should not pose a threat to any endangered or threatened species.

III. UNAVOIDABLE ADVERSE ENVIRONMENTAL EFFECTS

A. WATER QUALITY

Production activities will temporarily reduce water quality adjacent to the location. This will increase turbidity in a ilume down-current from the work site. Released waters and a minor oil spill could also contribute to water quality degradation.

B. EFFECTS ON MARINE ORGANISMS

Some organisms will be killed and some will be temporarily functionally impaired as a result of development operations. The most affected groups will be plankton and benthos immediately around the platform. Damage will be both mechanical and toxicological. Discharge of hole cuttings will damage

?lankton within the plume and bury some of the less mobile benthic fauna, hese impacts are considered to be localized, short term and reversible at the population level.

An oil spill could affect a broad spectrum of marine organisms. However, most effects would be localized and short term. Any effects on mammals and turtles would be significant.

C. WETLANDS AND BEACH

In the unlikely event of a spill occurring and reaching shore, organisms in wetland and beach habitats could be killed or functionally impaired. Human community disruption could also occur. Although all such effects would be localized, any effects on endangered species and/or critical habitats would b<5 significant.

D. AIR QUALITY

The air quality at the lease site will be degraded temporarily during operations, but should return to normal once operations are measurably completed. Offshore activities probably will not affect onshore air quality. Air quality at the onshor base will be only Insignificantly reduced by onshore activities. Any such effect will be temporary.

E. COMMERCIAL FISHING

Of the various types of fishing gear in use in the OCS areas, trawls have the greatest chance for operational conflicts with oil and gas activities. Losses may, however, be compensated under the Fishermen's Contingency Fund or other legal routes. Trawl nets can be snagged on underwater stubs causing damage or loss of the nets. In addition, it 1s conceivable that snags could damage underwater production equipment or pipelines causing a spill of oil or gas. Because safety equipment is installed, which shuts in production when a loss of pressure occurs, the likelihood of a major spill resulting thereby 1s considered very small. Less frequently, large objects which were lost

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overboard from petroleum Industry boats, pipeline lay barges, and platforms are caught by fishing gear resulting in damage to the gear and/or its catch of fish; however, occurrence of this type cf incident is low. Also, commercial fishermen would probably not harvest fish in the area of an oil spill, as spilled oil could coat or contaminate commercial fish species rendering them unmarketable. Other unavoidable adverse impacts include loss of fish space caused by installation of unburied pipelines, rigs, platforms, or by other OCS-related structures. There may be some localized competition for shore facilities. These effects and any effect that the development operations will have on stocks of important species are considered minor.

F. SHIP NAVIGATION

Very little interference can be expected between the platform and marin> vessels utilized during production operations and ships that use established fairways. However, at night and during rough weather, fog, and heavy seas, ships not using established fairways could collide with the platform.

G. CULTURAL RESOURCES

There is only a small probability that an unknown cultural resource exists 1n the lease area.

H. RECREATION AND AESTHETIC VALUES

The platform and marine vessels may represent an obstacle to some sport fisherman, but such an effect is expected to be negligible and not permanent.

Even though existing regulations and orders prohibit indiscriminate littering of the marine environment with trash, offshcre oil and gas cperations involving men, machines, equipment, and supplies 1s bound to result in some Uttering of the ocean. Human nature and accidents associated with offshore operations will contribute some floatable debris to the ocean environment which will eventually come ashore on major recreational beaches.

The effects that normal operations or a minor oil spill would have on any fish stocks important to sport fishermen are also considered to be negligible.

A minor oil spill and/or non-petroleum floating debris could foul beaches inshore of the lease area. The fouling of the beaches would be an aesthetic detriment that could adversely affect recreation. Any effects on beach recreation could adversely affect tourism and, consequently, the local economy.

IV. SUMMARY

The proposed activity will be carried out and completed with the guarantee of the following Items.

A. The best available and safest technologies will be utilized throughout the project. This includes meeting all applicable requirements for equipment types, cenera! project layout, safety systems, and equipment and monitoring systems.

B. All operations are covered by a Minerals Management Service approved Oil Spill Contingency Plan.

C. All applicable Federal, State and Local requirements regarding air emission and water quality and discharge for the proposed activities, cs well as any other permit conditions, will be complied with.

0. The proposed activities described in detail in the Development Plan will comply with Louisiana's Coastal Management Program and will be conducted 1n a manner consistent with such Program.

REFERENCES

1. Final Environmental Impact Statement, Proposed 011 and Gas Lease Sales 94, 98 and 102, Guif of Mexico OCS Region, OCS EIS, MMS 84-0057.

2. Final Environmental Impact Statement, Proposed 011 and Gas Lease Sales 94, 98 and 102, Gulf of Mexico OCS Region, OCS EIS, MMS 84-0057, visuals.

3. Fisheries of the United States, 1985, April, 1986.

4. The Ecology of Petroleum Platforms in the Northwestern Gulf of Mexico: A Community Profile, Bureau of Land Management Open File Report 82-03, July, 1982

5. Environmental Report West Cameron Area Blocks 516 and 524, March, 1987.

6. BLM Draft Environmental Impact Statement, OCS Oil and Gas Lease Sales A-52 and 52.

7. BLM Final Environmental Impact Statement, OCS Oil and Gas Lease Sales A-6? and 62.

8. BLM Final Environmental Impact Statement, OCS Oil and Gas Lease Sale 47.

9. Minerals Manaqement Service, 1983. Final Regional Environmental Impact Statement, Gulf Of Mexico. U.S. Department of the Interior.

10. Final Environmental Impact Statement, Proposed Oil and Gas Lease Sales 110 and 112, Gulf of Mexico OCS Region, OCS EIS, MMS 86-0087.

11. Final Environmental Impact Statement, Proposed Oil and Gas Lease Sales 110 and 112, Gulf of Mexico OCS Region, OCS EIS, MMS 86-0087, visuals.

12. Final Environmental Impact Statement, Proposed Oil and Gas Lease Sales 113, 115 and 115, Gulf of Mexico OCS Region, CCS EIS, MMS-87-0077.

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DRAWING NOT TO SCAlE