It is nearly inpossible to generalize about when permits are required and 

 when they are not. Complexities of ownership require that each case be judged 

 on its own peculiar circumstances. In nearly all cases, however, the pattern 

 described for seismic permits is followed. When large-scale activities such as 

 dredging, construction of levees, placement of wells and production equipment, 

 and pipeline construction are proposed, there are often one or more meetings 

 between company engineers and officials, regional office representatives, and 

 the refuge manager to discuss placement, alternative proposals, and many details 

 of the project. Sometimes site visits are made to familiarize the applicant 

 with the area or to clarify particular conditions. These meetings serve as 

 negotiating sessions where agreements are made on placement, construction 

 methods, and many other aspects of the proposed project. Based on the results 

 of those meetings and conferences between the manager and regional office, a 

 permit may be issued with a list of stipulations. These stipulations are in 

 essence the special requirements made of the applicant. They must be followed 

 or fulfilled during his activities on the refuge. 



Role of the Refuge Manager 



Daring all of these proceedings, the refuge manager is the person in the 

 middle. He is on-the-scene representing the USFWS and sees that the terms of 

 the permit are fulfilled. More importantly, he is the resident expert concern- 

 ing the refuge. Better than anyone else involved in the permit process, he 

 knows the characteristics of the land, the sites, wildlife and waterfowl use of 

 the area, and objectives for management of any specific place. When an appli- 

 cation for a permit is made, he is the first (and sometimes only) judge of the 

 effects of the activity on the site and surrounding areas. His opinions are 

 sought by the regional office regarding both the potential impacts on the refuge 

 environment and methods or alternatives that would lessen or eliminate the 

 undesirable consequences of oil and gas activities. 



Many of the methods and standards detailed in stipulations or communicated 

 orally by refuge managers to oil and gas operators have evolved from experience. 

 Specific problems have been identified by managers' observations of the effects 

 of activities on the habitats they manage. Managers have suggested methods to 

 lessen effects, many of which have been successful. They have communicated 

 these ideas among themselves, to regional refuge system officials, and to the 

 newer refuge employees that may become managers in the future. 



Transfer of managers from one refuge to another may result in a manager 

 unfamiliar with oil and gas development suddenly being faced with oil and gas 

 management responsibilities. Furthermore, energy development, not only on the 

 refuges but on adjacent water or land or on the continental shelf, may place 

 additional activities on existing refuges or initiate new actions on refuges 

 previously not exposed to the petroleum industry. Private lands or refuges 

 may feel these activities as well. Consequently, land managers for refuges, 

 other public lands, or private lands might find a review of oil and gas industry 

 practices, critical factors and impacts associated with oil and gas development, 

 and successful and proposed methods and standards useful in formulating criteria 

 for their own specific problems. 



