Public Scoping Comments

The formal scoping process for the development of the Exploratory Activities Environmental Impact Statement was initiated with the November 22, 2000, publication of the Notice of Intent to Prepare an EIS (NOI) in the Federal Register.   This notification was also broadly publicized in area newspapers and through direct mailing to an extensive mailing list.  Comments on the scope of the EIS analyses, issues, alternatives, mitigation, and information to be considered in the analyses were received at two public meetings (on December 6, 2000, in Santa Barbara and on January 22, 2001, in Santa Maria, CA.), by mail, and by email.  The Pacific OCS Region of MMS also conducted both formal and informal scoping meetings with local, State, and Federal agencies. 

While the scoping process for an EIS is generally continuous throughout the development of the document, the bureau is focusing initially on comments received during the early phases of developing the draft EIS to help frame the document.  Comments were encouraged to be submitted by February 22, 2001, for this purpose.  These comments are summarized below.

EIS Coverage

        Comprehensive analysis

• Analyze effects of developing all 36 leases in context of ongoing and future projected activities (oil and gas and non-oil and gas) offshore and onshore

• Area-wide, comprehensive EIS should analyze development of all the leases, with project-specific EIS's appropriately developed when applications are submitted

• Provide comprehensive analysis.  Include air and water quality, toxic contamination of soil, wildlife, marine life (including effect of acoustics), aging oil infrastructure, conflicts with State efforts to protect coast

• Analysis should include effects of activities through decommissioning; through refining and consumption

• Consider pollution from every step of oil exploration and development, including drilling, disposal of muds and cuttings, transporting product, . . .

• Include specific information about delineation activities:  full gamut of delineation activities, volume of oil recovered, mode of transport for the fluids, air quality effects, how will wells be capped

• Analyze onshore as well as offshore facility effects

• Analysis should be site specific as oil quality and need for processing differs for the areas involved

• Provide analysis of worst-case scenario

• Cumulative analysis should cover activities over the life of exploration, development, and production from all 36 leases and other, ongoing activities.

• Cumulative analysis should address onshore infrastructure, including aging infrastructure and potential upgrades to these facilities.   Including offshore and onshore transportation of the hydrocarbons.

Alternatives

• Objectively investigate viable alternatives

• Consider alternative energy production as alternatives to proposed action

• Include full spectrum of alternatives including no development, extending marine sanctuary to cover entire area, buying back leases

• Address alternative MODU's, alternative schedules, alternative well locations, alternative disposal methods for drilling muds and cuttings

Socioeconomic Resources

• Analyze psychological impacts of continued oil industry in the area

• Analyze effects on marine- and coastal-dependent recreation -- surfing, diving, whale watching, birding, beachcombing, fishing

• Analyze effects on tourism (visual and other)

• For high tourism areas with likely visual effects, schedule rig to avoid predominant tourist/recreational season

• Analyze social impacts include loss of quality of life

• Analyze effects on commercial fishing including possible displacement or impairment by oil and gas activities by seismic ships, exploratory vessel, platforms, pipelines, abandonment activities; conflicts between long-term businesses (fishing) and short-term activities (oil and gas); conflicts with vessel traffic servicing offshore activities; conflicts with debris following abandonment including capped but not thoroughly abandoned wells

• Analyze adverse effects on efforts to attract clean industries to area

• Evaluate construction and operating costs/savings associated with submerged platforms relative to conventional platforms, and weigh against social cost of littering coastline and social benefit of preserving/restoring natural beauty of coastline

• Address social issues such as San Luis Obispo law prohibiting offshore drilling or onshore support

• Address visual, scenic impacts; viewshed degradation

• Address growth inducing effects (increased industrial and urban activity and effect on character/enjoyment of area)

• Include study of how destruction of coastal resources impacts cultural heritage of California Indian Tribes

• Address possible offshore sites of cultural importance; include mitigation for known and suspected cultural sites offshore

• Study adverse health impacts on oil development, production, dependency

• Analyze catastrophic events and toxic effects on people

• Analyze impacts on socioeconomic resources and values

• Address economic effects on onshore economies of OCS purchase of air pollution offsets;  how allocation of remaining offsets results in economic hardship to onshore businesses (limited opportunities for new or expanded businesses)

• Evaluate the onshore economic effect of supplying electricity to offshore facilities

• Evaluate impacts on all possible crew and supply boat facility sites

• Analyze the direct and indirect contributions and deficits offshore oil and gas to local economies

• Analyze potential effects to fresh-water aquifers extending offshore

Coastal and Marine Resources

• Thoroughly cover marine mammal impacts, including impacts on marine mammal migration

• Examine impacts from oil spill: cleanup efforts can be more destructive than the spill itself; include cultural resources potentially affected by cleanup efforts

• Cover full range of impacts, such as disposal of drill muds and cuttings and acoustical impacts of operations, to marine life in already stressed system; address bio-productivity issues

• Address endangered and threatened species concerns, including sea otters, elephant seals, steelhead trout

• Employ recent data on harmful effects of exploration and drilling on marine life

• Analyze effects on the marine protected areas; analyze proposal in light of possible expansion of CINMS and possible creation of Gaviota National Seashore

• Study habitat impacts for fisheries

• Address potential impacts on white abalone and rockfish

• Provide complete inventory of marine, nearshore, onshore biology

• Update information used in original analyses on effects of exploratory activities in the area:  new marine sanctuaries, new air and water quality regulations, new information on oil spill cleanup capabilities,  new information on impacts of oil development on marine mammals and other marine life, new listed species, failure of sea otter translocation study, information from interagency Hard Bottom Habitat Committee and High Energy Seismic Survey Team

• Identify potentially contaminated sites associated with oil and gas development, include NORM's

• Consider impacts in light of EPA proposed rule on Ocean Sites of Significance (including Gorda Ridge)

• Include information on natural oil seeps in the area and their effects on marine environment

• Identify and ensure protection of hard-bottom areas

Air Quality

• New conformity analysis needed for air quality

• New air standards must be applied to proposal

• Air quality analysis should address availability of limited offsets

• Explore effects of scheduling on onshore air quality

Oil Spill Analysis -- Effects, Response, and Cleanup

• Analyze potential risk of hydrocarbon spills into ocean in range of conditions

• In discussing effects of oil spills and cleanup efforts, use historical information, not models; address potential adverse effects of clean-up efforts

• Address likelihood of effective cleanup in the often severe sea states north of Point Conception

• Cover oil spill abatement and cleanup in the area, including information on ocean and nearshore currents

Other

• National Academy of Sciences identified information needs -- evaluate extent to which these have been addressed

• Analyze effect of GPS's fiber-optic cable on operators' plans

• Assess potential for ships to collide with offshore facilities, especially north of Point Conception

• Assess potential for accidents resulting from military operations

• Address possible seismic events and probability that such an event would result in spilled oil

• Include possibility of new facility sited in North County; employ findings and recommendations of Santa Barbara County 2000 North County Siting Study

• Include in the analysis the environmental issues raised by the public in comments on COOGER

• Include information on investments to date, including bonus bids, by leaseholders on each of the subject leases

• Provide description of MODU and all projected operations of MODU, in detail

• Discuss speculative nature of cumulative analysis, given that proposals for development have not been received for all 36 undeveloped leases; explain subsequent analyses and approvals required for consideration of development, production, decommissioning.

Process

• Lawsuit (CA vs. Babbitt) should be resolved prior to preparation of EIS on activities on the leases; EIS should be developed on decision to suspend the leases

• Analytical approach is piecemeal.  EIS analysis on delineation drilling is premature.  Full development of all 36 undeveloped leases should be the subject of a programmatic EIS

• Federal Register Notice of Intent to Prepare and EIS not sufficient to enable full public comment (not enough information provided on proposed action); new, more complete FRN should be issued

Opposition to Exploration/Development of the Undeveloped Leases

• Need national energy plan

• Decrease demand, don't increase supply

• Asphalt available from other industrial manufacturing processes

• Adequate facilities exist to provide supply

• Development presents obstacles to development of alternative energy sources

• Focus instead on finding other energy sources, encouraging conservation through pricing, investing in mass transit, developing more efficient vehicles

• Need to reduce oil dependency -- inconvenience may facilitate development of alternative fuels and alternative transportation modes

• Conserve oil until needed and resources can be extracted more safely and less intrusively

• MMS lacks resources to adequately protect resources and oversee operations

• Lack of community support

• Significant risks to environment and  economic base -- threatened and endangered species (whales, other marine mammals, etc.), tourism and recreation, commercial fishing, air and water pollution, industrialization of sensitive shoreline habitats

• Local economies dependent on ocean; area economy dependent on reputation as pristine environment

• Attraction of clean industries require clean environment

• Threatens spiritual values

• Guadalupe Dunes and Avila Beach pollution illustrate of oil industry and regulatory negligence

• Future conflicts over decommissioning divides communities

• Risk too high to whales -- high decibel sound sources, traffic servicing oil and gas, potential spills and toxic muds poison krill

• Quality of oil too poor to warrant risks

• Presents hazards to navigation in fog

• Gyre in area seeds entire system and placed at risk by oil and gas activity

• Unavoidable impacts that can not be mitigated presented by exploration and development

• Significant oil spill risk

• Environmental impacts from normal operations unacceptable

• Currently, coastline is relatively undisturbed, with abundance of species and ecotypes

Support for Proposed Action

• Access more energy sources and lower cost

• Demand for oil persists

• Other energy sources not yet viable

• Reduce dependence on foreign oil

• Not appropriate to renege on contracts (leases) issued

• Area will provide a percentage of out needs; no one field will solve energy problems

• Costs of delaying development are high

• Technological improvements have been substantial (and will continue to be) -- minimize impacts

• Local, State, national benefits (jobs, recreational facilities, taxes/payments)

• History of industry supports understanding of safe operations; oil industry is one of safest and best regulated in U.S.

• Industry is capable of operating with philosophy and practice of zero defects

• Oil seeps are natural phenomenon in the area

• Oil spill response mechanisms are in place and effective

• New air quality regulations will result in net benefit to onshore areas

• No data to support injury to tourism experienced