American Oil and Gas Reporter - March 2017 - 92

which are intended to address presumed
adverse effects that will not occur, and
which will result in less exploration of
the Outer Continental Shelf," they state.
According to the industry associations,
the economic analysis included in the
DPEIS is inadequate, particularly regarding
assumptions about activity levels in the
face of overly restrictive mitigation measures, with the analysis appearing to completely ignore the extent to which less
G&G data potentially will reduce drilling
and production.
In addition, although the DPEIS describes the potential economic impacts of

its alternatives, it provides no cost estimates
for direct, indirect and induced economic
impacts over the 10 years it covers, and it
fails to adequately account for the variability inherent in offshore oil and natural
gas exploration and development, the
comments indicate. "BOEM has failed to
provide an economic impact analysis that
allows stakeholders to meaningfully assess
the practicability or feasibility of the proposed alternatives," the associations charge.
Accurate Images
Seismic surveying continues to be essential to achieving federal regulatory

goals because it is the only feasible technology available to accurately image the
subsurface before drilling starts, the groups
observe, adding advancements in seismic
vessels, configurations, acquisition planning and execution, and data processing
are providing more and better quality
data. Other advancements in geophysical
technology-including seismic reflection
and refraction, gravity, magnetics and
electromagnetics-afford industry significant precision in subsurface imaging,
the comments point out.
"Modern seismic imaging reduces risk
by increasing the likelihood that exploratory wells will successfully tap hydrocarbons and by decreasing the number
of wells that need to be drilled in a given
area, thereby reducing associated safety
and environmental risks and the overall
environmental footprint for exploration,"
the groups indicate.
Moreover, the comments indicate, because survey activities are temporary and
transitory, seismic surveying is the least
intrusive and most cost-effective means
to determine the likely locations of recoverable oil and gas resources.
The comments say G&G activities are
essential to both the expeditious and orderly development of OCS resources and
implementing environmental safeguards,
however the DPEIS provides no meaningful discussion of mandates under the
Outer Continental Shelf Lands Act, and
specifically fails to show how the proposed
alternatives are consistent with those
mandates. The associations point out
some of the alternatives undermine OCSLA's mandates by imposing measures
that will render important exploration
and development activities economically
or operationally infeasible.
Future Actions
If not corrected, the DPEIS's flaws
may have unintended and undesired negative consequences for agencies that rely
on the final PEIS for authorizing future
federal actions, specifically incidental take
authorizations under the Marine Mammal
Protection Act, the associations warn.
"For example, the DPEIS makes unrealistic, incorrect effects findings that
will almost certainly contradict findings
made in reviews of future federal actions
(assuming those reviews are performed
correctly)," the comments state. "Additionally, the DPEIS's failure to address
the effects of mitigation measures very
likely will contradict subsequent MMPA
Section 101(a)(5) evaluations, which require the permitting agency to consider
the effects of mitigation measures in making a determination that the authorized
take will have a 'negligible impact' on

92 THE AMERICAN OIL & GAS REPORTER



American Oil and Gas Reporter - March 2017

Table of Contents for the Digital Edition of American Oil and Gas Reporter - March 2017

Contents
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