Environmental factors are not a prime consideration in bid evaluations 

 The protection of the environment is more heavily weighted in the earlier 

 phases of the OCS leasing review. In post-sale analysis, new or additional 

 environmental inforrriation may be introduced, but BLM places primary emphasi 

 on development and production factors [71]. 



2.6 POST SALE MANAGEMENT 



Once a lease is issued, BLM maintains the lease agreements, but the 

 Geological Survey assumes supervision of lease operation. USGS requires 

 approval for an exploratory drilling plan before allowing bottom explora- 

 tion or exploratory drilling [72]. 



The USGS Area Oil and Gas Supervisor, part of the Conservation 

 Division, U.S. Geological Survey, implements regulations governing lease 

 operations [73]. Cooperative agreements between the Department of the 

 Interior and coastal states bring the states and then the U.S. Army Corps 

 of Engineers into this process. A stipulation indicating appropriate 

 consideration of Corps and state interests must be filed with the Area 

 Supervisor (along with lease exploration and development plans) to assure 

 protection and conservation of aquatic life and compliance with state laws 

 and regulations [74]. 



Industry operators furnish production reports to the USGS describing 

 the volume of oil and gas production, sales, and all royalties due the 

 government. Operators must also define operations, including new well 

 completions or recompletions. These requirements are enforced through 

 inspections during the first month after completion of a well and e^ery 

 6 or 15 months thereafter, depending on the number of wells drilled from 

 a platform [75]. 



Each USGS Area Oil and Gas Supervisor has the primary responsibility 

 for appropriate environmental safeguards as a field is developed [76]. 

 Though the U.S. Army Corps of Engineers and the U.S. Coast Guard require 

 permits for offshore structures, review criteria exclude environmental 

 considerations [77]. The key environmental safeguard in such a situation 

 is the effective enforcement of lease stipulations, USGS operating 

 "orders" or rules for a particular leasing area, and OCS guidelines and 

 regulations [78]. 



Pipelines, tankers and barges are the principal transportation links 

 between OCS oil and gas resources and onshore facilities. Both BLM and 

 USGS have responsibilities for pipelines on the OCS. USGS must approve 

 gathering lines (lines that run between production sites offshore) as part 

 of its management of field development [79]. BLM grants rights-of-way 

 from lease tracts to shore processing points [80]. However, USGS may 

 grant rights-of-way if the lines cross only the lessee's tracts before 

 reaching state waters. The Materials Transportation Bureau in the 

 Department of Transportation sets design criteria for safety [81]. The 



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