Construction : The placement of production platforms, especially the 

 gravity type, will have to be done in ways that least disturb the aquatic 

 and benthic habitats. Where gravity platforms are used, bottom habitat 

 will be permanently removed, especially where a platform is used that 

 has a large "mat" or base as its foundation. In addition, the immediate 

 surrounding area will be affected by the construction operations performed 

 on the site. The sponsor will have to take appropriate construction 

 steps, as defined in advance tests, to ensure that neighboring areas 

 will not be affected by excessive turbidity, release of toxic materials, 

 physical disruption, etc. 



Operation : The sponsor's major environmental problem in operation 

 will be in meeting pollutant discharge standards on waste disposal. 

 This includes not only petroleum discharges but also brines and sulfurous 

 mixtures which may be extracted from the well. These substances are 

 usually treated on the drilling rig, but it will be necessary to ensure 

 that equipment is always in efficient and proper operating order. EPA 

 may require the barging and disposal of drill cuttings to other ocean 

 disposal sites. Where drilling muds and cuttings contain more than 

 50 ppm hydrocarbons, they must be treated. 



The sponsor will have to exercise diligent care and provide adequate 

 responses when it is determined that platform operations may be 

 interfering with fish and wildlife resources. Production drilling will 

 have to be planned to avoid disturbances to fish and wildlife activities, 

 such as reproduction, rearing of young, and migration. For example, 

 where a species traditionally congregates in a relatively small area for 

 breeding purposes, it may be necessary to institute alternative production 

 drilling schedules. This will allow the species to perform its normal 

 biological functions without outside interference. Such a scheme may 

 incorporate drilling at locations other than those of important species' 

 activities, which will be particularly important in the case of endangered 

 species. 



Regulatory Factors 



Production drilling on the Outer Continental Shelf occurs in a 

 geographical area under exclusive Federal jurisdiction. Except for 

 recent amendments to the Coastal Zone Management Act, which have yet to 

 take effect, (see Section 2.2.2), states have no formal role in the 

 management process for production drilling. The United States Geological 

 Survey in the Department of the Interior has primary Federal management 

 responsibility. USGS works through a regional agent called the Area Oil 

 and Gas Supervisor who has final authority over day-to-day management 

 decisions. 



Federal Role : The leasing process, managed by BLM under the OCS 

 Land Act, results in lease stipulations based on comments by BLM, EPA, 



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