Hornbeck Offshore Services, L.L.C. v. Salazar et al

Filing 45

RESPONSE/MEMORANDUM in Opposition filed by Center for Biological Diversity, Defenders of Wildlife, Florida Wildlife Federation, Natural Resources Defense Council, Sierra Club re 7 MOTION for Preliminary Injunction. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11.1, # 12 Exhibit 11.2, # 13 Exhibit 12.1, # 14 Exhibit 12.2, # 15 Exhibit 13, # 16 Exhibit 14, # 17 Exhibit 15, # 18 Exhibit 16, # 19 Exhibit 17)(Suttles, John)

UNITED STATES DEPARTMENT OF THE INTERIOR MINERALS MANAGEMENT SERVICE GULF OF MEXICO OCS REGION NTL No. 2008-G04 Issue Date: April 1, 2008 Effective Date: May 1, 2008 Expiration Date: March 31, 2013

NOTICE TO LESSEES AND OPERATORS OF FEDERAL OIL, GAS, AND SULPHUR LEASES IN THE OUTER CONTINENTAL SHELF, GULF OF MEXICO OCS REGION Information Requirements for Exploration Plans and Development Operations Coordination Documents This Notice to Lessees and Operators (NTL) provides guidance on the information requirements for OCS plans required by 30 CFR 250, subpart B. This NTL supersedes NTL No. 2006-G14, effective July 12, 2006. It provides additional guidance on the information requirements regarding compliance with the provisions of the Endangered Species Act (ESA) and the Marine Mammal Protection Act (MMPA), provides guidance on replacing high-resolution survey lines with 3-D survey data and information for shallow hazards analyses, and makes minor technical amendments. Authority and Background On August 30, 2005, Minerals Management Service (MMS) published final regulations in the Federal Register amending subpart B of 30 CFR part 250 (see 70 FR 51478). These regulations became effective on January 1, 2006. On April 13, 2007, MMS published revisions to subpart B (effective May 14, 2007) to require that you provide information to accompany OCS plans to describe how you will conduct your proposed activities in a manner consistent with the ESA and the MMPA, including monitoring and mitigation measures. In the subpart B regulations, the contents of an Exploration Plan (EP), a Development and Production Plan (DPP), or a Development Operations Coordination Document (DOCD) are given at 30 CFR 250.211 through 250.228 and 30 CFR 250.241 through 250.262. Under 30 CFR 250.201(c), MMS may limit the amount of information or analysis you must provide in such OCS plans to that which is necessary to ensure compliance with the OCS Lands Act (OCSLA), as amended, other laws, applicable regulations, and lease stipulations or provisions. Under this authority, and the authority in 30 CFR 250.201(b), the MMS Gulf of Mexico OCS Region (GOMR) has established the contents of EP's and DOCD's for activities in the Gulf of Mexico (GOM) OCS. These contents, along with clarifying information, are provided in this NTL and its attachments.

2 See 30 CFR 250.105 for the definition of "affected State." Item (1) of that definition delineates a geographical area as one component in determining when a State is an affected State. For a map showing these geographic areas, refer to the MMS Internet website at: http://www.gomr.mms.gov/homepg/offshore/plans_permits/czmmaps.html. Proprietary Data The information collected pursuant to 30 CFR 250, subpart B, is used to inform MMS, affected States, and the public of planned exploration, development, and production operations on the OCS. It also ensures that OCS operations are planned to comply with statutory and regulatory requirements; will be safe and protect the human, marine, and coastal environment; and will result in diligent exploration, development, and production of leases (see 30 CFR 250.199(e)(2)). Data and information that must be made available to the public without the consent of the lessee, and under what circumstances and times, are outlined at 30 CFR 250.196(a) and (b). Pursuant to 43 CFR Part 2, Appendix E, sections (4) and (9), the MMS GOMR has determined that only the following information is exempt from disclosure: (a) The geologic objectives, BHL, TVD, and MD information on form MMS-137 (OCS Plan Information Form) in Attachment A; (b) Production rates and life of reservoirs under General Information at 30 CFR 250.243(c)(1); (c) Proprietary information in your description of any new or unusual technology you will use under General Information at 30 CFR 250.213(d) and 250.243(e); (d) All items under Geological and Geophysical Information at 30 CFR 250.214 and 250.244, except for the non-proprietary version of your shallow hazards assessment; and (e) Correlative well information you use to justify your H2S classification request under Hydrogen Sulfide Information at 30 CFR 250.215(b) and 250.245(b). Guidance Document Statement The MMS GOMR issues NTL's as guidance documents in accordance with 30 CFR 250.103 to clarify, supplement, and provide more detail about certain MMS regulatory requirements and to outline the information you provide in your various submittals. Under that authority, this NTL sets forth a policy on and an interpretation of a regulatory requirement that provides a clear and consistent approach to complying with that requirement. However, if you wish to use an alternative approach for compliance, you may do so, after you receive approval from the appropriate MMS GOMR office under 30 CFR 250.141. Paperwork Reduction Act (PRA) Statement The collection of information referred to in this NTL provides clarification, description, or interpretation of requirements in 30 CFR 250, subpart B and Form MMS-137. The Office of Management and Budget (OMB) has approved the information collection requirements for this regulation and form and assigned OMB control number 1010-0151. This NTL does not impose additional information collection requirements subject to the PRA.

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Contact If you have any questions regarding this NTL, please contact the MMS GOMR Plans Section at [phone]. [original signed] Lars T. Herbst Regional Director NTL with Attachments A and B

CONTENTS OF EXPLORATION PLANS (EP's) AND DEVELOPMENT OPERATIONS COORDINATION DOCUMENTS (DOCD's) Definitions Terms used in this NTL have the following meaning: Deepwater means those water depths 400 meters (1,312 feet) or greater. Flower Garden Banks Protective Zone means that area of the GOM OCS consisting of the following blocks:
HI A-351 HI A-352 HI A-353 HI A-354 HI A-355 HI A-361 HI A-362 HI A-363 HI A-364 HI A-365 HI A-366 HI A-367 HI A-368 HI A-373 HI A-374 HI A-375 HI A-376 HI A-384 HI A-395 HI A-403 GB 135 HI A-377 HI A-385 HI A-396 HI A-573 GB 136 HI A-378 HI A-386 HI A-397 HI A-596 GB 138 HI A-379 HI A-387 HI A-398 GB 95 GB 139 HI A-380 HI A-388 HI A-399 GB 96 GB 140 HI A-381 HI A-389 HI A-400 GB 97 GB 177 HI A-382 HI A-390 HI A-401 GB 133 GB 178 HI A-383 HI A-394 HI A-402 GB 134 GB 179 HI = High Island; GB = Garden Banks; EB = East Breaks GB 180 EB 173 EB 217

Stetson Bank Protective Zone means that area of the GOM OCS consisting of the following blocks:
HI A-486 HI A-487 HI A-488 HI A-501 HI A-502 HI A-514 HI A-503 HI A-527 HI A-512 HI A-528 HI A-513 HI A-529 HI = High Island

Plan Contents (30 CFR 250.211 and 250.241) (a) Plan Information Form. Use Form MMS-137 (see Attachment A of this NTL) to provide information concerning your proposed activities. . (b) Location. Provide a map (separate from any other required map), at a scale of 1 inch = 2,000 feet on an 8½-inch by 11-inch sheet of paper, that depicts the surface location and water depth of each proposed well and production facility, and the proposed locations of all associated drilling unit and construction barge anchors, including any that will be used for the installation or construction of production facilities or well protector structures. If you do not know the proposed anchor locations, you may show the maximum anchor radius instead.

2 (c) Safety and pollution prevention features. Provide a brief description of the important safety and pollution prevention features for your drilling unit, production facilities, and lease term pipelines. (d) Storage tanks and production vessels. Using the format below, provide information on the storage tanks and/or production vessels at the facility you will use to conduct your proposed activities (barges, drilling rigs, platform, etc.) and that will store oil, as defined at 30 CFR 254.6. Include only those tanks with a capacity of 25 barrels or more.
Type of Storage Tank Fuel Oil Production Type of Facility Semi-submersible Platform A Tank Capacity (Barrels) 250 40,000 Number of Tanks 2 2 Total Capacity (Barrels) 500 80,000 Fluid Gravity (API) No. 2 Diesel. 37º

(e) Pollution prevention measures. For EP's and DOCD's that propose activities for which the State of Florida is an affected State, provide a discussion of the measures you will use to prevent the discharge of oils and greases from drilling rigs or platforms during rainfall and routine operations. (The State of Florida has identified this information as necessary data and information under 15 CFR 930.58(a)(2).) (f) Additional measures. Provide a discussion of the safety, pollution prevention, and early spill detection measures that you will take beyond those required by 30 CFR part 250 when you propose the following: : (1) Activities for which the State of Florida is an affected State. (2) Activities within the Protective Zones of the Flower Garden Banks and Stetson Bank. (3) To install a surface facility located in water depths greater than 400 meters (1,312 feet), or a surface facility in any water depth that supports a subsea development in water depths greater than 400 meters (1,312 feet). (4) Initial DOCD's and supplemental DOCD's with new multiwell structures for which the State of Louisiana is an affected State (15 CFR 930.58(a)(2)). (5) Initial EP's and DOCD's and supplemental DOCD's with new multiwell structures for which the State of Texas is an affected State (15 CFR 930.58(a)(2)). General Information (30 CFR 250.213 and 250.243) (a) Applications and permits. Using the format below, provide information on the filing or approval status of the Federal, State, and local application approvals or permits you must obtain to conduct your proposed activities. List all individual or site-specific application approvals you must obtain, but do not list general National Pollutant Discharge Elimination System (NPDES) permits or Corps of Engineers (COE) permits.
Application/Permit EPA Air Permit Individual NPDES Permit Issuing Agency EPA EPA Status To be submitted Approved

3 (b) Drilling fluids. (1) Using the format below, provide information on the types (including chemical constituents) and amounts of the drilling fluids you plan to use to drill your proposed wells when you propose the following: (i) Activities for which the State of Florida is an affected State. (ii) Activities within the Protective Zones of the Flower Garden Banks and Stetson Bank. (iii)To install a surface facility located in water depths greater than 400 meters (1,312 feet), or a surface facility in any water depth that supports a subsea development in water depths greater than 400 meters (1,312 feet). (iv) Initial DOCD's and supplemental DOCD's with new multiwell structures for which the State of Louisiana is an affected State (15 CFR 930.58(a)(2)) and that propose the use of oil-based or synthetic-based drilling fluids. (v) Initial EP's and DOCD's and supplemental DOCD's with new multiwell structures for which the State of Texas or the State of Mississippi is an affected State (15 CFR 930.58(a)(2)).
Type of Drilling Fluid Water-based (seawater, freshwater, barite) Oil-based (diesel, mineral oil) Synthetic-based (internal olefin, ester) Estimated Volume of Drilling Fluid to be Used per Well 35,000 bbls 500 bbls 20,000 bbls

(2) For each oil-based drilling fluid you list in the table above, (i) Use the format below to describe its major components, and
Product Name Bentonite PureDrill IA-35 Amount to be Used 100 50-lb bags 500 bbls Reference Number CAS # 1302-78-9 CAS # 178603-63-9

(ii) Provide a Material Safety Data Sheet (MSDS), MSDS No., or Internet address for the MSDS (or equivalent information) for each product. (c) Production. For DOCD's only, use the format below to provide information about each type of your anticipated production.
Type Oil Gas Average Production Rate 5,000 bbls/day 500 mmcfd Peak Production Rate 10,000 bbls/day 900 mmcfd Life of Reservoir 20 years 15 years

(d) Oils characteristics. For DOCD's only, use the format below to provide the chemical and physical characteristics of the oils (see definition under 30 CFR 254.6) that will be produced, handled, transported, or stored at the facilities you will use to conduct your proposed development and production activities.

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Characteristic (1) (2) (3) (4) Gravity (API) Flash Point (ºC) Pour Point (ºC) Viscosity (Centipoise at 25 ºC)

(5) Wax Content (wt %) (6) Asphaltene Content (wt %) (7) Resin Content (wt %) (8) Boiling point distribution including, for each fraction, the percent volume or weight and the boiling point range in degrees C (9) Sulphur (wt %)

Analytical Methodologies Should Be Compatible With: ASTM D4052 ASTM D93/IP 34 ASTM D97 ASTM D445 Precipitate with 2-butanon/dichloromethane (1 to 1 volume) at -10 ºC IP-Method 143/84 Jokuty et al. (1996) ASTM D2892 (TBP distillation), or ASTM D2887/5307 ASTM D4294

Note: For the distillation information in item no. 8 above, the MMS GOMR may accept the following information in lieu of items nos. 5, 6, 7, and 8: weight percent total of saturates, aromatics, waxes, asphaltenes, and resins; and total BTEX (ppm) using analytical methods compatible with the Hydrocarbon Groups methodology from Jokuty et al. (1996).

Provide information on the oil composition most likely to result in the largest volume spill (e.g., the oil from the expected largest reservoir, stored oil or pipeline oil combined from a number of wells). Identify the oil you analyze using one of the following formats:
Oil from one well Area/Block. MMS platform ID. API Well No. Completion perforation interval MMS reservoir name. Sample date. Sample No. (if more than one is taken). Oil from more than one well sampled on a facility Area/Block. MMS platform ID. Field/Unit. Sample date. Sample No. (if more than one is taken). Listing of API Well Nos. Storage tank ID No. (if sampled at a storage tank. Oil from a pipeline system Pipeline segment number. For each pipeline that feeds into the system, the ID codes for the closest upstream LACT units and/or facility measurement points. Storage tank ID No. (if sampled at a storage tank).

Provide the above two tables only when you propose the following: : (1) Activities for which the State of Florida is an affected State. (2) Activities within the Protective Zones of the Flower Garden Banks and Stetson Bank. (3) To install a surface facility located in water depths greater than 400 meters (1,312 feet), or a surface facility in any water depth that supports a subsea development in water depths greater than 400 meters (1,312 feet). (e) New or unusual technology. If you propose to use new or unusual technology, as defined in 30 CFR 250.200, to carry out your proposed activities, provide a narrative description of the methodology or technique and the rationale for its selection. In the public information copies of your EP or DOCD, you may exclude any proprietary information from this description. In that case, include a brief discussion of the general subject matter of the omitted information. If you

5 will not use any new or unusual technology to carry out your proposed activities, include a statement so indicating. (f) Bonding statement. Provide one of the following statements regarding your bond coverage, as applicable: The bond requirements for the activities and facilities proposed in this [EP][DOCD] are satisfied by a [lease] [area-wide] bond, furnished and maintained according to 30 CFR part 256, subpart I, and NTL No. 2000-G16, "Guidelines for General Lease Surety Bonds." The bond requirements for the activities and facilities proposed in this [EP][DOCD] are satisfied by a [lease] [area-wide] bond, furnished and maintained according to 30 CFR part 256, subpart I; NTL No. 2000-G16, "Guidelines for General Lease Surety Bonds;" and additional security under 30 CFR 256.53(d) and National NTL No. 2008-N07, "Supplemental Bond Procedures." The bond requirements for the activities and facilities proposed in this [EP][DOCD] are satisfied by a [lease] [area-wide] bond, furnished and maintained according to 30 CFR part 256, subpart I; NTL No. 2000-G16, "Guidelines for General Lease Surety Bonds;" and a current MMS-approved deferment from providing additional security under 30 CFR 256.53(d) and National NTL No. 2008-N07, "Supplemental Bond Procedures. If, any point, [company name] no longer qualifies for a supplemental bonding deferment, [company name] will either provide the required additional security or a third party guarantee within 60 days after such disqualification." (g) Oil spill financial responsibility (OSFR). Provide the following statement regarding your OSFR coverage: [Company name with MMS company number] [has demonstrated] [will demonstrate] oil spill financial responsibility for the facilities proposed in this [EP][DOCD] according to 30 CFR part 253, and NTL No. 2008-N05, "Guidelines for Oil Spill Financial Responsibility (OSFR) for Covered Facilities." (h) Deepwater well control statement. If you propose to drill a well in deepwater, provide the following deepwater well control statement: [Company name with MMS company number] [has][will have] the financial capability to drill a relief well and conduct other emergency well control operations.

6 (i) Suspensions of production. For DOCD's only, provide a brief discussion of any approved or anticipated suspensions of production you have, or will seek, to hold the lease(s) or unit involved with your DOCD in active status. (j) Blowout scenario. Provide a scenario for a potential blowout of the well (proposed in your EP or DOCD) from which you expect to have the highest volume of liquid hydrocarbons. Include the estimated flow rate, total volume, and maximum duration of the potential blowout. Discuss also the potential for the well to bridge over, the likelihood for surface intervention to stop the blowout, the availability of a rig to drill a relief well, and rig package constraints. Estimate the time it would take to drill a relief well. Provide this blowout scenario only when you propose the following: (1) Activities for which the State of Florida is an affected State. (2) Activities within the Protective Zones of the Flower Garden Banks and Stetson Bank. (3) To install a surface facility located in water depths greater than 400 meters (1,312 feet), or a surface facility in any water depth that supports a subsea development in water depths greater than 400 meters (1,312 feet). (4) Initial DOCD's and supplemental DOCD's with new multiwell structures for which the State of Louisiana is an affected State (15 CFR 930.58(a)(2)). (5) Initial EP's and DOCD's and supplemental DOCD's with new multiwell structures for which the State of Texas is an affected State (15 CFR 930.58(a)(2)). (k) Chemical products. The information at 30 CFR 250.213(c) and 250.243(d) regarding chemical products is not required to accompany EP's and DOCD's submitted in the MMS GOMR. Geological and Geophysical Information (30 CFR 250.214 and 250.244) (a) Geological description. Provide a discussion of the geological objectives, including a brief description of the hydrocarbon trapping elements. (b) Structure contour maps. Provide current structure contour maps, at a scale of 1 inch = 2,000 feet (depth-based, expressed in feet subsea), drawn on the top of each prospective hydrocarbon sand for EP's, and of each productive hydrocarbon sand for DOCD's, showing the entire lease block, the location of each proposed well, and the locations of geological crosssections. You may use another scale or coverage area for these contour maps on a case-by-case basis if your activities cover more than one lease block, and if you obtain prior approval from the Regional Supervisor. (Examples of acceptable maps can be found on the MMS website at: http://www.gomr.mms.gov/homepg/regulate/regs/ntls/structmap1.pdf and http://www.gomr.mms.gov/homepg/regulate/regs/ntls/structmap2.pdf.) (c) Interpreted two-dimensional (2-D) and/or three-dimensional (3-D) seismic lines. Provide page-size copies of migrated and annotated (shot points, time lines, well paths) 2-D and/or 3-D seismic lines with depth scale within 152 meters (500 feet) of the surface locations of your proposed wells. Provide this information as an enclosure to one proprietary copy of your EP.

7 You are not required to provide this information if the MMS GOMR has approved the surface locations of your proposed wells in previously submitted EP's and DOCD's. (d) Geological structure cross-sections. Provide interpreted geological structure crosssections showing the location and depth of each proposed well for EP's, and expected productive formations for DOCD's. In addition, show at least one key horizon and the objective sands, and label them using standard biostratigraphic terms. Express all depths in feet. (An example of an acceptable cross-section may be found on the MMS website at: http://www.gomr.mms.gov/homepg/regulate/regs/ntls/xsection.pdf). (e) Shallow hazards report. If your proposed activities are in water depths less than 300 meters (984 feet), provide two copies of a shallow hazard report based on information obtained from a high-resolution geophysical survey, or a reference to such report if you have already submitted it to the Regional Supervisor. If your proposed activities are in water depths 300 meters (984 feet) or more, provide three copies of the report. If the report covers multiple leases, provide a listing. Refer to NTL No. 2008-G05, "Shallow Hazards Program," for guidelines. (NOTE: If you combine an archaeological report with your shallow hazards report, then you will need to provide a total of three copies for proposed activities in water depths less than 300 meters (984 feet) and four copies for activities in water depths 300 meters (984 feet) or more.) (f) Shallow hazards assessment. Provide, for each well proposed at an unapproved surface location, an assessment of any seafloor and subsurface geological and manmade features and conditions that may adversely affect your drilling operations, prepared using the guidance in NTL No. 2008-G05. For wells or platforms proposed at approved surface locations, include a statement to this effect in lieu of an assessment. Include a non-proprietary version of this item for those EP's or DOCD's that require CZMA consistency review. (g) High-resolution seismic lines. Provide an annotated (shot points, time lines, well surface locations, and proximity of wells to line) copy of the high-resolution survey line (shallow penetration subbottom profiler; medium penetration seismic profiler; and sidescan sonar in areas of complex seafloor such as fault scarps, mud mounds, and mud lobes) closest to each of the proposed well locations. Provide this information as an enclosure to one proprietary copy of your EP or DOCD. You are not required to provide this information if the MMS GOMR has approved the surface locations of your proposed wells in previously submitted EP's and DOCD's. You do not need to provide sidescan sonar data for areas in water depths greater than 200 meters (656 feet). For activities proposed in water depths greater than 200 meters (656 feet), you may replace the high-resolution survey lines with 3-D survey data and information if you have previously run a 3-D seismic reflection survey over 100 percent of the area. If you make this replacement, provide a seafloor "rendering" or shaded relief map for the proposed well or platform site, a power spectrum diagram, the top hole prognosis, the sampling rate, the acquisition parameters (e.g., cable, source depth), the year the survey was run, and the type of processing used. The MMS GOMR may request that you perform further processing to enhance the resolution if the area is complex (numerous faults, gas vents, slumps, hard bottoms, etc.). You may replace highresolution survey lines with 3-D survey data and information only if:

8 (i) The 3-D data provide a sufficiently resolute image of the shallow section to allow a clear analysis of the shallow conditions; (ii) The data are loaded to a workstation at no less than 16-bit (preferably 32-bit) data resolution and are unscaled; (iii)There is no form of trace and/or sample decimation of the original processed volume; (iv) The original processed sample interval and bin size are maintained throughout the area; (v) The dataset possesses a frequency content of 50 Hz or more across the first second of section below the seafloor; (vi) Seafloor reflection is free of gaps and defined by a wavelet of stable shape and phase to allow auto-tracking of the seafloor event with minimum user intervention and guidance; (vii)Acquisition artifacts such as cross-line statics and/or amplitude striping, though possibly identifiable in shallow section, do not detract from the overall interpretation of the picked event when mapped in time or amplitude. Similarly, time slices or windowed attribute extractions are devoid of, or show minimal, acquisition artifacts to the detriment of their interpretation; (viii) Merge points between datasets of differing origin or vintage that cross the area are marked by minimal, preferably no, time shifts or amplitude changes across the join that might otherwise be to the detriment of the interpretation; (ix) Processed bin sizes are less than 40 meters (130 feet) in both the inline and crossline dimension; (x) The processed output sample interval is 4 milliseconds or less; (xi) Attention to definition of an accurate velocity model in the shallow section in processing allows optimum structural and stratigraphic resolution to have been achieved in the 3-D migrated volume. The shallow section shows no indication of under or over migration artifacts; (xii) Multiple energy is unidentifiable or at a level that does not interfere with the analysis of the shallow section; and (xiii) The proposed activities are not in an area of high archaeological potential (see NTL No. 2005-G07). (h) Stratigraphic column. For EP's only, provide a generalized biostratigraphic/ lithostratigraphic column from the seafloor to the total depth of each prospect. Label objective horizons on the column. (An example of an acceptable stratigraphic column may be found on the MMS website at: http://www.gomr.mms.gov/homepg/regulate/regs/ntls/stratcolumn.pdf.) (i) Time vs. depth tables. For EP's proposing activities in areas where there is no well control, provide seismic travel time versus depth tables showing intervals of not more than 10 milliseconds. (j) Geochemical information. The information at 30 CFR 250.214(j) and 250.244(j) regarding geochemical reports is not required to accompany EP's and DOCD's submitted in the MMS GOMR.

9 (k) Future G&G activities. The information at 30 CFR 250.214(k) and 250.244(k) regarding future G&G activities is not required to accompany EP's and DOCD's submitted in the MMS GOMR. Hydrogen Sulfide (H2S) Information (30 CFR 250.215 and 250.245) (a) Concentration. Provide the estimated concentration of any H2S you might encounter or handle while conducting your proposed activities. (b) Classification. Pursuant to 30 CFR 250.490(c), request that the Regional Supervisor classify the area of your proposed activities as either H2S absent, H2S present, or H2S unknown. Provide sufficient information to justify your request (e.g., concentrations from at least one correlative well). (c) H2S Contingency Plan. If you request that the Regional Supervisor classify the area of your proposed activities as either H2S present or H2S unknown, provide one of the following: (1) An H2S Contingency Plan prepared according to 30 CFR 250.490(f); (2) A reference to an approved or submitted H2S Contingency Plan that covers the proposed activities; or (3) The following statement: [Company name] will submit to the appropriate MMS GOMR district office an H2S Contingency Plan prepared according to 30 CFR 250.490(f) before conducting the proposed [exploration][development and production] activities. (d) Modeling report. If you have determined or estimated that you will encounter or handle H2S at concentrations greater than 500 parts per million (ppm), model a potential worst-case accidental H2S release from the facilities you will use to conduct your proposed activities. Provide two copies of the modeling report or the modeling results (see 30 CFR 250.490), or a reference to such report or results if they have already been submitted to the Regional Supervisor. Include the meteorological data you use in the modeling (as an ASCII-formatted model input file). The analysis in the report should be specific to the particular site of your activity, and should consider any nearby human-occupied OCS facilities, shipping lanes, fishery areas, and other points where humans may be subject to potential exposure from an H2S release from your proposed activities. If your projected emissions would effect a concentration of H2S of 10 ppm or greater at an onshore area, the modeling analysis should be consistent with the risk management plan (RMP) methodologies of the Environmental Protection Agency (EPA) outlined in 40 CFR part 68. Mineral Resource Conservation Information (30 CFR 250.246) (a) Technology and reservoir engineering practices and procedures. For DOCD's only, provide a brief description of the technology and reservoir engineering practices and procedures

10 you will use to increase the ultimate recovery of oil and gas (e.g., secondary, tertiary, or other enhanced recovery practices). If enhanced recovery practices are not going to be used initially, provide an explanation of the methods you considered and the reasons why you are not using them. (b) Technology and recovery practices and procedures. For DOCD's only, provide a brief description of the technology and recovery practices and procedures you may use to ensure optimum recovery of oil and gas and/or sulphur. (c) Reservoir development. For DOCD's only, provide a brief discussion of your exploratory well results, other reservoir data, proposed well spacing, completion methods, and other relevant well plan information. Biological, Physical, and Socioeconomic Information (30 CFR 250.216 and 250.247) (a) High-Density Deepwater Benthic Communities Information. If you propose activities that could disturb seafloor areas in water depths 300 meters (984 feet) or greater, provide the report described in Attachment A of NTL No. 2009-G40, "Deepwater Benthic Communities." (b) Topographic features map. If you propose bottom-disturbing activities (including rig placement, and rig or construction barge use of anchors, chains, cables, and wire ropes) within 305 meters (1,000 feet) of the "No Activity Zone" of an identified topographic feature, provide the map described in Attachment 2, Section A, Item No. 1 of NTL No. 2009-G39 "BiologicallySensitive Underwater Features and Areas." (c) Topographic features statement (shunting). For EP's only, if you propose to drill more than two wells from the same surface location and that surface location is outside the 1-mile Zone but within the Protective Zone of an identified topographic feature, provide a statement described in Attachment 2, Section A, Item No. 2 of NTL No. 2009-G39 "Biologically-Sensitive Underwater Features and Areas." (d) Live bottoms (Pinnacle Trend) map. If you have the live bottom (Pinnacle Trend) stipulation attached to your lease, and you propose bottom-disturbing activities (including rig placement, and rig or construction barge use of anchors, chains, cables, and wire ropes) within 61 meters (200 feet) of any pinnacles, include the map described in Attachment No. 4, Section A of NTL No. 2009-G39 "Biologically-Sensitive Underwater Features and Areas." The OCS blocks affected by this stipulation are Main Pass Area, Blocks 190, 194, 198, 219226, 244-266, 276-290; Viosca Knoll Area, Blocks 473-476, 521, 522, 564-566, 609, 610, 654, 692-698, 734, and 778; and Destin Dome Area Blocks 577, 617, 618, and 661. (e) Live bottoms (low relief) map. If you have the Live Bottom (low relief) stipulation attached to your lease, provide the map described in Attachment 6, Section A of NTL No. 2009G39, "Biologically-Sensitive Underwater Features and Areas." (f) Potentially sensitive biological features map. If you propose bottom-disturbing activities (including rig placement, and rig or construction barge use of anchors, chains, cables, and wire

11 ropes) within 61 meters (200 feet) of potentially sensitive biological features, include the map described in Attachment 8, Section A of NTL No. 2009-G39, "Biologically-Sensitive Underwater Features and Areas." (g) Remotely operated vehicle (ROV) monitoring survey plan. If you propose activities that could disturb seafloor areas in deepwater, provide an ROV monitoring survey plan prepared using the guidance in NTL No. 2008-G06, "Remotely Operated Vehicle Surveys in Deepwater." (h) Threatened or endangered species, critical habitat, and marine mammal information. Provide site-specific information on the presence of federally listed threatened or endangered species and critical habitat designated under the ESA and marine mammals protected under the MMPA in the area of the proposed activities. (i) Archaeological report. When you propose bottom-disturbing activities in areas that the MMS GOMR has identified as having a potential for containing historic or prehistoric archaeological resources, provide three copies of an archaeological report or a reference to such a report if it has already been provided to the Regional Supervisor. Refer to NTL No. 2005-G07, "Archaeological Surveys and Reports," and NTL No. 2006-G07, "Revisions to the List of OCS Lease Blocks Requiring Archaeological Resource Surveys and Reports," for guidelines. (NOTE: Provide four copies of a combined archaeological/shallow hazards report for activities in water depths greater than 300 meters (984 feet).) For EP's and DOCD's proposing activities for which the State of Florida is an affected State, provide a discussion of the presence and description of any historic and prehistoric archaeological resources that could be affected by the proposal, and measures to protect these resources. Describe the surveys you used to locate and identify these resources. (The State of Florida has identified this information as necessary data and information under 15 CFR 930.58(a)(2).) (j) Air and water quality information. For EP's and DOCD's proposing activities for which the State of Florida is an affected State, provide a discussion of air and water quality in and adjacent to the area of the proposed activities. (The State of Florida has identified this information as necessary data and information under 15 CFR 930.58(a)(2).) (k) Socioeconomic information. Provide the following socioeconomic information: (The State of Florida has identified this information as necessary data and information under 15 CFR 930.58(a)(2).) (1) The estimated number of persons you expect to employ in support of your offshore, onshore, and transportation activities within the State of Florida and, where possible, the approximate number of new employees and families likely to move into the affected area; (2) An estimate of the major supplies, services, energy, water, or other resources you expect to purchase within the State of Florida and that are necessary for you to carry out the EP or DOCD; and

12 (3) The types of contractors or vendors within the State of Florida you will need to carry out the EP or DOCD. Waste and Discharge Information (30 CFR 250.217 and 250.248) (a) Projected generated wastes. Using the format below, provide information on the projected solid and liquid wastes likely to be generated by your proposed activities. Include both operational wastes permitted by the appropriate NPDES permit and any other identified wastes.
Type of Waste Spent drilling fluids Cuttings containing Synthetic-based mud Chemical product waste Trash Composition Water-based drilling muds Cuttings coated with ester-based Synthetic drilling muds Ethylene glycol Methanol Refuse generated during painting operations Projected Amount 8,000 bbls/well 600 bbls/well 100 bbls/month 25 bbls/month 50 bbls/month

Describe also your plans for treating, storing, or downhole disposal of these wastes at your facility locations(s). Provide this table and description only when you propose the following: (1) Activities for which the State of Florida is an affected State. (2) Activities within the Protective Zones of the Flower Garden Banks and Stetson Bank. (3) To use new or unusual technology that changes the nature or magnitude of the waste stream. (4) To use a sulphur recovery unit(s). (5) Deepwater development operations. (You may omit this table if you propose operations in an exempted area.) Refer to the MMS website at http://www.gomr.mms.gov/homepg/regulate/environ/ea_grid/ea_grid.asp. (6) Initial EP's, Initial DOCD's, or Supplemental DOCD's with new multiwell structures for which the State of Texas or the State of Mississippi is an affected State (15 CFR 930.58(a)(2)). (7) Initial or supplemental DOCD's for which the State of Alabama is an affected State (15 CFR 930.58(a)(2)). (8) Initial DOCD's or Supplemental DOCD's with new multiwell structure that includes disposal in Louisiana State waters or onshore Louisiana (15 CFR 930.58(a)(2)). (b) Projected ocean discharges. If any of your solid and liquid wastes are to be discharged overboard, use the format below to provide the following information.

13
Type of Waste Spent drilling fluids and cuttings containing synthetic-based mud Chemical product wastes Total Amount to be Discharged 5,000 bbls 50 bbls Discharge Rate 200 bbls/day 2 bbls/day Discharge Method Shunt through downpipe to 40 feet above the mudline. Add to produced water stream.

Provide this table only when you propose the following: (1) (2) (3) (4) Activities for which the State of Florida is an affected State. Activities within the Protective Zones of the Flower Garden Banks and Stetson Bank. To use new or unusual technology that changes the nature or size of the waste stream. Deepwater development operations. (You may omit this table if you propose operations in an exempted area). Refer to the MMS website at http://www.gomr.mms.gov/homepg/regulate/environ/ea_grid/ea_grid.asp. (5) Initial EP's, Initial DOCD's, or Supplemental DOCD's with new multiwell structures for which the State of Texas or the State of Mississippi is an affected State (15 CFR 930.58(a)(2)). (6) Initial or supplemental EP's or DOCD's for which the State of Alabama is an affected State (15 CFR 930.58(a)(2)).

(c) Modeling report. If you model the trajectory or fate of discharges of the projected solid or liquid wastes generated by your proposed activities, provide two copies of the modeling report or the modeling results, or a reference to such report or results if it has already been submitted to the Regional Supervisor. Include the oceanographic data you used in the modeling in the report. If you plan to model, consult with the Regional Supervisor for further guidance on preparing the modeling report. Provide this report only when you propose activities for which the U.S. Environmental Protection Agency requires an individual NPDES permit. (d) NPDES permits. The information at 30 CFR 250.217(c) and 250.248(c) regarding NPDES permits is not required to accompany EP's and DOCD's submitted in the MMS GOMR. (e) Cooling water intakes. The information at 30 CFR 250.217(e) and 250.248(e) regarding cooling water intakes is not required to accompany EP's and DOCD's submitted in the MMS GOMR. Air Emissions Information (30 CFR 250.218 and 250.249) (a) Emissions worksheets and screening questions. If any of the activities proposed in your EP or DOCD take place at the site of an existing facility or well, prepare two different emissions worksheets. The calculated emissions that are associated with the activities proposed in the current EP or DOCD submission are referred to as Plan Emissions. Complex Total Emissions are the Plan Emissions plus projected emissions from all existing co-located facilities and activities (i.e., those that are at the same surface location as your proposed activities, including any group of structures interconnected with walkways or bridges). If there are no existing facilities or activities co-located with your currently proposed activities, then state that the

14 Complex Total Emissions are the same as the Plan Emissions, and prepare only one emissions worksheet. (1) Emissions worksheets. Calculate the Plan Emissions and the Complex Total Emissions associated with your proposed activities using the methodology, emission factors, and worksheets in Form MMS-138 for EP's and Form MMS-139 for DOCD's. These forms are on the MMS website at: http://www.gomr.mms.gov/homepg/mmsforms/frmindx.html. Depending on your answers to the screening questions in paragraph (2) below, you may need to include the worksheets in your EP or DOCD. In calculating your Plan Emissions and Complex Total Emissions: (i) You may base the emissions on the maximum rated capacity of the equipment associated with your activities, or by using emission reduction measures or modified emission factors. If you base your emissions calculations on the use of emission reduction measures or modified emission factors, you will need to submit the worksheets and the documentation described in paragraphs (d)(1) and/or (d)(2) below. (ii) If you have not determined the specific drilling unit you will use, use the maximum emission estimates for the type of drilling unit (i.e., jackup, platform rig, barge, submersible, semisubmersible, or drillship) in your calculations. You can find the maximum emission estimates for each drilling unit type on the MMS website at: http://www.gomr.mms.gov/homepg/regulate/environ/airquality/reporting.html. (2) Screening questions. For EP's, use the format below to answer questions regarding your calculated air emission amounts.
Screening Questions for EP's Is any calculated Complex Total (CT) Emission amount (tons) associated with your proposed exploration activities more than 90% of the amounts calculated using the following formulas: CT = 3400D2/3 for CO, and CT = 33.3D for the other air pollutants (where D = distance to shore in miles)? Do your emission calculations include any emission reduction measures or modified emission factors? Are your proposed exploration activities located east of 87.5o W longitude? Do you expect to encounter H2S at concentrations greater than 20 parts per million (ppm)? Do you propose to flare or vent natural gas for more than 48 continuous hours from any proposed well? Do you propose to burn produced hydrocarbon liquids? Yes No

15 For DOCD's, use the format below to answer questions regarding your calculated air emission amounts.
Screening Questions for DOCD's Is any calculated Complex Total (CT) Emission amount (tons) associated with your proposed development and production activities more than 90% of the amounts calculated using the following formulas: CT = 3400D2/3 for CO, and CT = 33.3D for the other air pollutants (where D = distance to shore in miles)? Do your emission calculations include any emission reduction measures or modified emission factors? Does or will the facility complex associated with your proposed development and production activities process production from eight or more wells? Do you expect to encounter H2S at concentrations greater than 20 parts per million (ppm)? Do you propose to flare or vent natural gas in excess of the criteria set forth under 30 CFR 250.1105(a)(2) and (3)? Do you propose to burn produced hydrocarbon liquids? Are your proposed development and production activities located within 25 miles (40 kilometers) from shore? Are your proposed development and production activities located within 124 miles (200 kilometers) of the Breton Wilderness Area? Yes No

In calculating CT for addressing the first question, express the distance to shore (D) in tenths of a statute mile for distances up to 20 miles, and in whole statute miles for distances 20 miles and beyond. Use the nearest point of any land, which is the distance from the facility complex to the mean high water mark of any State, including barrier islands and shoals, to determine the distance to shore. (b) If you answer no to all of the above screening questions from the appropriate table, provide (1) Summary information regarding the peak year emissions that will be generated by and associated with your Plan Emissions and Complex Total Emissions. This information is compiled on the summary form of the two sets of worksheets, and you can submit either these summary forms or the format below. You do not need to include the entire set of worksheets.
Plan Emission Amounts1 (tons) Calculated Exemption Amounts2 (tons) Calculated Complex Total Emission Amounts3 (tons)

Air Pollutant Carbon monoxide (CO). Particulate matter (PM). Sulphur dioxide (SO2). Nitrogen oxides (NOx). Volatile organic compounds (VOC).

Footnotes: 1 For activities proposed in your EP or DOCD, list the projected emissions calculated from the worksheets. 2 List the exemption amounts for your proposed activities calculated by using the formulas in 30 CFR 250.303(d). 3 List the complex total emissions associated with your proposed activities calculated from the worksheets.

16 (2) The name, telephone number, and e-mail address of a contact who can answer questions regarding calculations of the projected Plan Emissions, Complex Total Emissions, and exemption amounts. (3) Following your submittal of the summary information, the MMS GOMR may need you to submit the entire set of worksheets regardless of your response to the above screening questions. The MMS GOMR will make this determination on a case-by-case basis. (c) If you answer yes to any of the above screening questions from the appropriate table, provide (1) Worksheets. A set of worksheets showing the emission calculations for your Plan Emissions and, if different, a set of worksheets showing the emission calculations for the Complex Total Emissions. (2) Contact(s). The name, telephone number, and e-mail address of the person(s) who calculated the projected Plan Emission, Complex Total Emission, and exemption amounts. (d) In addition, if the screening results indicate that you are to submit worksheets, you may need to submit one or more of the following: (1) Emission reduction measures. If your calculation of the projected Plan Emission or Complex Total Emission amounts includes emissions reduction measures, submit your worksheets and also use the format below to describe the emission reduction measures. You may use actual fuel usage information (e.g., run times, fuel consumption). If you do, provide 6 to 12 months of data for determining the average fuel usage. The actual fuel usage you use in the emissions calculations cannot be less than the average fuel usage.
Emission Source Compressor Prime mover Prime mover Generator Reduction Control Method Clean burn technology Low sulphur fuel Actual fuel consumption Actual run time Amount of Reduction 100 tons NOx/year 10 tons SO2/year 300 tons NOx/year 100 tons NOx/year Monitoring System Periodic stack test Visual check of fuel color and fuel receipts Fuel log Run time log

(2) Verification of nondefault emission factors. If you use any air emission factors less than the default values in your calculation of the projected Plan Emission or Complex Total Emission amounts, provide documentation supporting the use of the smaller emission factors. However, if the actual emission factor is known to be greater than the default emission factor, use the actual emission factor. (3) Non-exempt activities. If the calculated Complex Total Emission amount for any pollutant (CO, PM, SO2, NOx, or VOC) is greater than the respective emission exemption amount (E) calculated using the following formulas: E = 3400D2/3 for CO, and E = 33.3D for the

17 other air pollutants (i.e., the formulas in 30 CFR 250.303(d)), provide a description of how you will comply with 30 CFR 250.303(e) through (i), as appropriate. (4) Modeling report. If you are required by 30 CFR 250.303 to use an MMS-approved air quality model to model projected air emissions, adhere to the guidelines in Appendix W of 40 CFR part 51 in conducting the modeling and preparing the report. Provide two copies of the modeling report and the modeling results, along with a digital copy (in ASCII format) of the input and output files (including the meteorological data you used in the modeling), or a reference to the report, files, and results if they have already been submitted to the MMS GOMR. Oil Spills Information (30 CFR 250.219 and 250.250) Provide the following information regarding potential spills of oil (see definition under 30 CFR 254.6): (a) Oil spill response planning. The oil spill response plan (OSRP) required by either paragraph (1) or (2) below: (1) If you propose activities for which the State of Florida is an affected State, a sitespecific OSRP prepared according to the requirements of 30 CFR 254.21-29 and that specifically addresses the activities proposed in your EP or DOCD, or a subregional OSRP prepared according to the guidance of NTL No. 2006-G21, "Regional and Subregional Oil Spill Response Plans." If your lease is subject to the special oil spill response lease stipulation, incorporate in your site-specific or subregional OSRP a detailed description of the equipment you will procure to satisfy the requirements of the stipulation and a timetable for its onsite deployment or availability. (2) If you propose activities in the Central or Western Planning Areas of the GOM, a reference to your approved regional OSRP (see 30 CFR 254.3), or activities for which the State of Florida is an affected State, a reference to your approved subregional OSRP, to include the following: (i) Regional or subregional OSRP information. The following statement regarding your OSRP: All the proposed activities and facilities in this [EP or DOCD] will be covered by the Oil Spill Response Plan filed by [Company name with MMS company number] in accordance with 30 CFR 254 and approved on [Date]. (ii) Spill response sites. Using the format below, information on the location of your primary spill response equipment and the location of your planned staging area(s) that would be used should you have an oil spill resulting from the activities proposed in your EP or DOCD;
Primary Response Equipment Location Houma, LA Preplanned Staging Location(s) Fourchon, LA; Grand Isle, LA

18 (iii)OSRO information. The name(s) of your oil spill removal organization(s) for both equipment and personnel. (iv) Worst-case scenario determination. If you have an approved regional OSRP, provide a comparison of the appropriate worst-case scenario from your approved regional OSRP with the worst-case scenario from the proposed activities in your EP or DOCD. Refer to the sample chart below. Use this comparison to aid you in determining whether the worst-case scenario from your approved regional OSRP is superseded by the worst-case scenario from the proposed activities in your EP or DOCD. For EP's, because estimated blowout flow rates are speculative, you should not ordinarily determine that the worst-case scenario from the proposed activities in your EP supersedes the appropriate worst-case scenario from your approved regional OSRP unless its volume is substantially larger. (Reminder: In making this determination, also consider proximity to beaches, waterfowl, other marine and shoreline resources, and areas of special economic or environmental importance.)
Category Type of Activity1 Facility Location (area/block) Facility Designation2 Distance to Nearest Shoreline (miles) Volume3 Storage tanks (total) Flowlines (on facility) Lease term pipelines Uncontrolled blowout (volume per day) Total Volume Type of Oil(s) - (crude oil, condensate, diesel) API Gravity(s)4 Regional OSRP Production ­ Subsea completion EI 250 Well No. 2 45 miles 0 bbls 40 bbls 1,600 bbls 2,700 bbls 4,665 bbls Crude oil. 37º EP or DOCD Development ­ Platform drilling rig MC 900 Rio Loco Project 160 miles 200 bbls 15 bbls 400 bbls 600 bbls 1,215 bbls Crude oil. 37º

Footnotes: 1. Types of activities include pipeline, platform, caisson, subsea completion or manifold, and mobile drilling rig. 2. E.g., Well No. 2, Platform JA, Pipeline Segment No. 6373. 3. Take your regional OSRP worst-case scenario volume from the appropriate section of your regional OSRP. For EP's, the worst-case scenario volume is the daily volume possible from an uncontrolled blowout. Determine this volume using the provisions of 30 CFR 30 CFR 254.47(b). For DOCD's, determine the volume of your worst-case scenario using the provisions of 30 CFR 30 CFR 254.47(a) or (b), as appropriate. 4. Provide API gravity of all oils given under "Type of Oil(s)" above. Estimate for EP's.

(A) If your proposed activities are within ten miles seaward of the coastline, reference the "near-shore" worst-case scenario provided in your approved regional OSRP. If your proposed activities are ten miles or more seaward from the coastline, reference the "farshore" worst-case scenario provided in your approved regional OSRP. Where applicable, reference the worst case scenario for your leases and facilities located in the Flower Garden Banks Oil Spill Planning Area (see Appendix H of NTL No. 2006-G21, "Regional and Subregional Oil Spill Response Plans"). Where applicable, reference the worst-case scenario for your mobile rig exploration drilling operations. For each worst-case scenario, identify clearly the specific scenario in the reference. (B) If you determine that the worst-case scenario from the activities proposed in your EP or DOCD supersedes the worst-case scenario from your approved regional OSRP,

19 modify your approved regional OSRP to incorporate this new worst-case scenario and provide the following statement: [Name of company] submitted the new worst-case scenario to the MMS GOMR on [date] for inclusion in our regional or subregional OSRP. The EP or DOCD will not be approved until the Regional Supervisor has received and approved your regional or subregional OSRP worst-case scenario modification. (C) If you determine that the worst-case scenario from the activities proposed in your EP or DOCD does not supersede the worst-case scenario in your approved regional or subregional OSRP, provide the following statement: Since [name of company] has the capability to respond to the appropriate worst-case spill scenario included in its regional OSRP approved on [date], and since the worst-case scenario determined for our [EP] [DOCD] does not replace the appropriate worst-case scenario in our regional or subregional OSRP, I hereby certify that [name of company] has the capability to respond, to the maximum extent practicable, to a worst-case discharge, or a substantial threat of such a discharge, resulting from the activities proposed in our [EP] [DOCD]. (b) Oil spill response discussion. Discuss your response to an oil spill resulting from the activities proposed in your EP or DOCD. Include all the information described in 30 CFR 254.26(b), (c), (d), and (e) that is applicable. As the source of the spill, use whichever of the following gives the greater volume of oil: (1) The blow-out scenario you describe in paragraph (j) under General Information (30 CFR 250.213 and 250.243) above; or (2) The volume of the largest oil/fuel storage tank on the drilling rig or facility. Provide this oil spill response discussion only when you propose the following: (i) Activities for which the State of Florida is an affected State. (ii) Activities within the Protective Zones of the Flower Garden Banks and Stetson Bank. (iii)To install a surface facility located in water depths greater than 400 meters (1,312 feet), or a surface facility in any water depth that supports a subsea development in water depths greater than 400 meters (1,312 feet). (iv) Initial DOCD's and supplemental DOCD's with new multiwell structures for which the State of Louisiana is an affected State (15 CFR 930.58(a)(2)). (v) Initial EP's and DOCD's and supplemental DOCD's with new multiwell structures for which the State of Texas is an affected State (15 CFR 930.58(a)(2)).

20 (c) Modeling report. If you model a potential oil or hazardous substance spill, provide two copies of the modeling, or a reference to such a report if it has already been provided to the Regional Supervisor. Include the oceanographic data used in the modeling in the report. If you plan to model, contact the Regional Supervisor for guidance on preparing the report. Provide this modeling report only when you propose the following: (1) Activities for which the State of Florida is an affected State. (2) To install a surface facility located in water depths greater than 400 meters (1,312 feet), or a surface facility in any water depth that supports a subsea development in water depths greater than 400 meters (1,312 feet). Environmental Monitoring Information (30 CFR 250.221 and 250.252) (a) Monitoring systems. Provide a description of any existing and planned monitoring systems that are measuring, or will measure, environmental conditions and/or will provide project-specific data or information on the impacts of your proposed activities. (b) Incidental takes. If there is reason to believe that protected species may be incidentally taken by your proposed activities, describe how you will monitor for incidental take of: (1) Threatened and endangered species listed under the ESA; and (2) Marine mammals, as appropriate, if you have not already received authorization for incidental take as may be necessary under the MMPA. (c) Flower Garden Banks National Marine Sanctuary. If you propose to conduct activities within the Protective Zones of the Flower Garden Banks and Stetson Bank, discuss your provisions for monitoring the impacts of an oil spill on the environmentally sensitive resources of the Flower Garden Banks National Marine Sanctuary. Lease Stipulations Information (30 CFR 250.222 and 250.253) Provide a brief description of the measures you took, or will take, to satisfy the conditions of any lease stipulations related to your proposed activities. Environmental Mitigation Measures Information (30 CFR 250.223 and 250.254) (a) For EP's and DOCD's that propose activities for which the State of Florida is an affected State, provide a description of the measures you will take to avoid, minimize, and mitigate impacts to marine and coastal environments and habitats, biota, and threatened and endangered species. (The State of Florida has identified this information as necessary data and information under 15 CFR 930.58(a)(2).) (b) Incidental takes. If there is reason to believe that protected species may be incidentally taken by your proposed activities, include mitigation measures designed to avoid or minimize the incidental take of:

21 (1) Threatened and endangered species listed under the ESA; and (2) Marine mammals, as appropriate, if you have not already received authorization for incidental take as may be necessary under the MMPA. Decommissioning Information (30 CFR 250.255) The information at 30 CFR 250.255 regarding decommissioning is not required to accompany EP's and DOCD's submitted in the MMS GOMR. Related Facilities and Operations Information (30 CFR 250.256) (a) Related OCS facilities and operations. For DOCD's only, provide a description and location of any proposed or existing drilling units, production platforms, pipeline accessory platforms, host facilities, pipelines and associated umbilicals (including those that transport chemical products and produced water), or other facilities and operations located on the OCS (regardless of ownership) that directly relate to your proposed development or production activities. This description should include the size, length, proposed routes, product(s) being transported, maximum flow rates, and the shut-in time of any proposed pipelines. Provide this related facilities and operations information only for the following: (1) All initial and supplemental DOCD's. (2) All revised DOCD's, but only for those facilities and operations that will change as the result of the activities proposed in the revised DOCD. (b) Transportation system. For DOCD's only, provide a discussion of the transportation system that will be used to transport your production to shore (including the routes of any new pipelines) and a description and location of the primary onshore terminal (including any refineries, gas plants, and compressor stations that will be built or undergo major expansion as the result of the activities proposed in your DOCD). (c) Produced liquid hydrocarbons transportation vessels. If produced liquid hydrocarbons, including well test fluids, will be transported by means other than a pipeline, use the format below to provide information on the alternative method.
Transport Method Shuttle tanker Vessel Capacity 50,000 bbls Average Volume to be Loaded (per transfer) 40,000 bbls No. of Transfers (Yearly Average) 52

In addition, provide a description of the method you will use to transfer the liquid hydrocarbons to the transporting vessel.

22 Support Vessels and Aircraft Information (30 CFR 250.224 and 250.257) (a) General. Using the format below, provide information regarding the vessels (e.g., tug boats, anchor-handling vessels, construction barges, lay barges, supply boats, crew boats) and aircraft you will use to support your proposed activities. If specific vessels have not yet been determined, use the maximum capacities, numbers, and trip frequencies for the types of vessels you will use.
Type Tug boats Supply boats Service boats Crew boats Maximum Fuel Tank Storage Capacity 3000 bbls 500 bbls 500 bbls 500 bbls Maximum No. in Area at Any Time 2 2 1 1 Trip Frequency or Duration Every two weeks Three times weekly Daily Weekly

(b) Diesel oil supply vessels. Using the format below, provide additional information on the vessels you will use to supply diesel oil. Make sure you include any vessels that will transfer diesel oil you will use for purposes other than fuel (e.g., base for corrosion control fluids). If the specific fuel supply vessel has not yet been determined, use the maximum size, fuel capacity, and trip frequency for the type of vessel you will use.
Size of Fuel Supply Vessel 180 feet Capacity of Fuel Supply Vessel 1,500 bbls Frequency of Fuel Transfers Weekly Route Fuel Supply Vessel Will Take From the shorebase in Fourchon, LA, to XYZ Field, then to WC Block 134.

Provide this table only when you propose the following: (1) Activities for which the State of Florida is an affected State. (2) Activities within the Protective Zones of the Flower Garden Banks and Stetson Bank. (3) To install a surface facility located in water depths greater than 400 meters (1,312 feet), or a surface facility in any water depth that supports a subsea development in water depths greater than 400 meters (1,312 feet). (4) Initial and supplemental DOCD's for which the State of Alabama is an affected State (15 CFR 930.58(a)(2)). (5) Initial DOCD's and supplemental DOCD's with new multiwell structures for which the State of Louisiana is an affected State (15 CFR 930.58(a)(2)). (c) Drilling fluids transportation. If you propose activities for which the State of Florida is an affected State, use the format below to provide information on the projected drilling fluids you will transport from the onshore support facilities you will use to your drilling unit or facilities.

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Type of Material Barite Synthetic-base drilling fluid component Quantity Being Transported 10-50 lb bags 55 gallons Transportation Method On flats on supply boat Drums on St. Mary Mud Company's supply boat

(d) Solid and liquid wastes transportation. If you plan to transport any of your solid and liquid wastes from the site of your proposed activities to other offshore structures or to temporary or permanent onshore facilities for storage or disposal, use the format below to provide the following information:
Type of Waste Approx. Composition Spent oil-based drilling fluids Chemical product wastes Trash and debris Total Amount 1,000 bbls 100 bbls 1,000 ft3 Name/Location XYZ Company, St. Mary, LA Mars Facility, Morgan City, LA Morgan City municipal landfill. Rate 200 bbls/day 2 bbls/day 4 bbls/day N/A Transport Method Cuttings boxes on barges Drums on crew boat Drums on crew boat Storage bins on crew boat

Provide this table only when you propose the following: (1) Activities for which the State of Florida is an affected State. (2) Activities within the Protective Zones of the Flower Garden Banks and Stetson Bank. (3) To use new or unusual technology that changes the nature or magnitude of the waste stream on the facility. (4) Deepwater development operations. (You may omit the table if you propose operations in an exempted area.) Refer to the MMS website at
http://www.gomr.mms.gov/homepg/regulate/environ/ea_grid/ea_grid.asp

(5) To use a sulphur recovery unit on the facility. (6) Initial and supplemental DOCD's for which the State of Alabama is an affected State (15 CFR 930.58(a)(2)). (7) Initial DOCD's or supplemental DOCD's with new multiwell structures that include disposal in Louisiana coastal waters or onshore Louisiana (15 CFR 930.58(a)(2)). (8) Initi