Mr. J. F. Bennett, Chief June 10, 2010

Branch of Environmental Assessment

Minerals Management Service

381 Elden Street

MS 4042

Herndon, Virginia 20170

Sent via certified mail # 7002 2030 000 6235 3962

Re: Notice of Intent To Prepare and Scope an Environmental Impact Statement (EIS) for the Outer Continental Shelf (OCS) Oil and Gas Leasing Program for 2012-2017

Dear Mr. Bennett:

ManaSota-88 recommends exclusion of all areas of the Eastern, Central and Western Gulf of Mexico and the Straits of Florida for any new oil and gas leasing areas for the OCS Gas and Oil Leasing Program for 2012 - 2017.

ManaSota-88 recommends that all lease sales remaining for the Eastern, Central and Western Gulf of Mexico scheduled before the end of 2012 be canceled. 

ManaSota-88, Inc. (ManaSota-88) is a public interest environmental and public health organization incorporated under the laws of the State of Florida as a not-for-profit corporation. The membership of ManaSota-88 consists of citizens and residents of Florida, including residents living or working in Manatee and Sarasota County. Members of ManaSota-88 use and enjoy the waters of the Gulf of Mexico, which is the subject of the OCS 2012 - 2017 Lease Program.

ManaSota-88 finds no reason to believe the current OCS Leasing Program will protect Florida's economy and environment from the potential serious environmental damage associated with offshore oil drilling.

Oil drilling will place the Eastern Gulf of Mexico, an area of high environmental sensitivity and marine productivity, at risk. Presently the region supports numerous species of wildlife, major commercial and recreational fisheries and several species of endangered animals.

Extensive environmental studies are required before offshore oil drilling can be permitted. These preliminary steps have not been taken. Existing scientific data is incomplete and outdated due to the 

environmental impacts from the Deepwater Horizon oil spill. 

The Mineral Management Service (MMS) currently uses a  "best guess management" policy regarding drilling safety as it relates to the public's health and the environment. 

Without adequate data, the environmental trade-offs and cost/risk analysis required prior to granting oil and gas leases will result in the continued use of the present MMS  "best guess management" policy. 

There is no evidence to indicate that mitigation measures exist to reduce the significant adverse environmental impacts associated with offshore oil drilling. Until the technology exists to prevent further economic and environmental damage, expanded drilling should not be permitted in the Gulf of Mexico

Significant Issues for the Outer Continental Shelf Oil and Gas 

Leasing Program for 2012-2017

Cumulative Impact Analyses

Environmental concerns with regard to OCS leasing activities center around oil spills, pipelines, chronic impacts resulting from routine discharges of drilling fluids, and onshore impacts. 

Offshore oil and gas drilling permits and transportation and refinery operation permits must be linked for cumulative impact analysis. This currently is not being done. 

Not enough is known about the value and sensitivity of live bottom areas of the Gulf of Mexico to permit additional leasing of areas for exploration and development activities. 

Previous EIS's have not adequately evaluated the long or short term biological effects of areas contaminated from oil-spills.

The EIS for the Oil and Gas Leasing Program must make it quite clear that information regarding environmental and public health impacts is lacking. Previous OCS Oil and Gas Leasing EIS's are not in conformity with the National Environmental Policy Act (NEPA).

Onshore water quality degradation routinely occurs as a result of increased nonpoint and point sources of pollution, especially in those areas along Florida's west coast where water quality problems already exist (Perdido, Escambia, Hillsborough and Tampa Bay). Point source pollution increases also occur from effluent discharges related to OCS support activities.

In addition to pipeline blowouts or leaks causing serious environmental problems, laying pipes from offshore will also cause increased turbidity of surface waters, destruction of sea grass beds and resuspension of contaminated sediments.

The overall impact of oil and gas activities seriously affects aquatic preserves and submerged lands under state jurisdiction to protect marine habitats, oyster beds, marshes and mangroves.

Fair Market Value Options 

The approach of the current OCS Leasing Program has been an economic and environmental failure.

The Minerals Management Service depends heavily upon the oil industry to perform an evaluation of the resources available and to report the full value of the deposits to be leased to the Department of Interior (DOI). Resource estimates have been so highly inaccurate that they are meaningless.  To depend upon such information is to depend upon the same irresponsible premise that the oil industry will fully identify the amounts and values of mineral resources under their DOI contracts. Therefore, the MMS will never be able to properly comply with the cost/risk analysis required. 

The present "generic" approach to OCS leasing has leased far too much submerged land in the Gulf of Mexico for exploration.  As a result, the MMS has not been able to adequately monitor for and control the environmental degradation resulting from offshore leasing activities. 

The large size of the current oil and gas leases in the Gulf of Mexico means the federal government is not realizing a proper financial return from the sale. 

The OCS Leasing Program has not provided the best opportunity to bring about the lowest level of environmental consequences and thwart the tendency of the oil industry to lease more land than it can explore and develop.  There is no need to expand existing leasing activities.

90 million acres of federal lands are currently leased to oil companies. Less than a quarter of these lands are being used for oil and gas production.  Flooding the market with huge area-wide offshore oil leases will drive down the price of oil and gas leases and reduce competition. The American taxpayers will loose out on billions of dollars of oil revenues. The glut of oil leases already offered has provided the oil industry an opportunity to lease large blocks of submerged lands at bargain basement prices. 

Potential Impacts to Tourism and Recreation Activities

Florida's economy is based on having clean beaches and a healthy environment, not oil refineries, storage tanks, oil platforms and pipelines. 

Tourism employs about 1 million people living in Florida. Tourism generates about $65 billion-a-year for the state of Florida.  

Whatever oil revenues are realized is small when compared to the cost in damage one oil spill will have on Florida's economy, environment and job employment.

A proper economic assessment of offshore oil drilling can only be made when the following are considered: costs of the loss of recreation and tourism dollars, the irretrievable commitment of chemicals used in the separation and processing of oil and gas; the hazards associated with transportation of hazardous and volatile chemicals associated with oil exploration and processing, the increased costs associates with reduced national security, the costs of the health impacts associated with increased air and water pollution,  and the costs of the unavoidable impacts to Florida's coast.

Accidental Oil Spills

The fact is oil that reaches wetlands and estuaries near the Gulf Coast will render the area uninhabitable to plants and animals. Oil will remain for years, destroying the eggs and larvae of marine organisms, adversely impacting waterfowl, and completely destroying or disrupting the food chain. Marine life will be affected in a myriad of poorly understood ways; smothering bottom dwellers and subtly changing marine and shoreline ecosystems. Large accidental oil spill impacts have never been adequately addressed in previous Environmental Impact Statements. 

Crude oil spills or blowouts pose a serious threat to a variety of shorelines along the Gulf Coast. Included among the shorelines are sandy beaches, wetlands and mangroves. Oil slicks can and will penetrate into marshes and mangroves, causing a more pervasive and persistent impact in the interior of such areas. Furthermore, designated environmental preservation areas, such as aquatic preserves and estuarine and marine sanctuaries, extend into sub tidal and intertidal areas where important natural features such as shellfish beds, sea grasses, rock outcroppings and coral reef communities exist.

Ecological Impacts From Potential Degradation Of Marine And Coastal Habitats

Coastal water impacts occur with routine oil and gas drilling activities such as an increase in turbidity resulting from pipeline installation, navigation canal maintenance, the discharge of drilling muds, the increased concentrations of some metals, hydrocarbons, and dissolved solids within the drilling area adjacent to the point of discharge, and the marine water impacts resulting from supply and service-vessel bilge and ballast water discharges.

Drilling in marine and coastal environments can have devastating impacts. Petroleum hydrocarbons are extremely toxic to a wide variety of marine organisms at very low concentrations. In addition to direct lethal effects, petroleum hydrocarbons can exert sub lethal effects, including reduced growth, altered feeding behavior, and lower reproductive success. Oil spilled in sheltered lagoons and wetlands may persist in sediments for decades, where it can continue to exert negative effects on benthic organisms.

Hurricanes 

Florida perhaps faces a greater potential for the occurrence of natural hazards than any other state. Florida ranks first in hurricane occurrences and is the most vulnerable to the devastating effects resulting from coastal storms.

Hurricanes can and have caused oil spills.

The U.S. Government's Minerals Management Service states that Hurricanes Katrina and Rita damaged or destroyed 113 oil platforms, 457 oil pipelines and caused 124 offshore oil spills in the Gulf of Mexico. More than 9,000,000 gallons of oil were spilled from onshore tanks and pipelines as a result of the two storms. The U.S. Coast Guard reported that there were over 9 million gallons of oil released from six major and five medium spills.

There is no reason to believe that future oil drilling will protect Florida's economy and environment from the potentially serious environmental damage associated with offshore oil drilling and onshore oil spills associated with hurricanes. 

Seagrass Communities

Oil spills occurring near a seagrass community will require long term cleanup and the impacts will be permanent in nature.  Spilled oil causes lethal and sub-lethal effects in benthic organisms in seagrass communities. 

Turbidity impacts from pipeline installation and maintenance dredging, anchoring, infrastructure and pipeline emplacement, infrastructure removal, drilling discharges, and produced-water discharges negatively impact sea grasses. 

Chemosynthetic And Nonchemosynthetic Communities

These communities are susceptible to physical impacts from structure placement, anchoring, and pipeline installation associated with shallow and deep well drilling. Damage to the ecological functions of deep-sea benthic communities can be expected if additional drilling is allowed. Environmental destruction will be difficult if not impossible to recover due to the depths deep-sea communities are located at. Little to no base-line data exists concerning these communities in the Gulf of Mexico. 

Sea Turtles

All five species of sea turtles exist within Gulf of Mexico and the Florida Straits.  Negative impacts from routine activities and accidental spills will affect sea turtles due increased exposure to hydrocarbons resulting in lethal and/or sub lethal impacts.

The routine activities of shallow and deep well drilling will have significant adverse impact on the size and recovery of any sea turtle species or population living in the Gulf of Mexico. 

Hydrocarbons persisting in the Gulf of Mexico following the dispersal of an oil slick will result in sub-lethal impacts for years. 

Onshore Health and Environmental Impacts

Oil and gas operations require roads, storage tanks, pipelines, processing facilities, and other industrial facilities. These can severely damage beaches, wetlands, and coastal habitats, with consequences for coastal economies that depend on tourism, recreation and fishing. 

Oil and gas processing plants can result in the degradation of air quality. Onshore gas processing activities typically emit constant levels of volatile organic compounds, nitrogen oxides, carbon monoxide, sulfur dioxide and total suspended particulates.

Processing and oil separation require large volumes of water. The addition of one or several gas processing plants in Florida will have significant impacts on local water supplies. 

The oil and gas industry should not be permitted to externalize the costs of the air, water and land pollution they create at the expense of the environment and the public's health. Onshore refinery and offshore drilling permits need to be linked together in the review and issuance of oil and gas permits. 

Coastal and Marine Birds

Routine oil and gas drilling operations can impact endangered or threatened bird species such as the piping plover, whooping crane, and brown pelican by causing changes in behavior, exposure to or intake of oil contaminants, ingestion of discarded debris, temporary and permanent displacement of bird populations and permanent impacts on their food supply.

Fish Resources and Essential Fish Habitat (EFH)

A purpose of the Magnuson-Stevens Act is: "to promote the protection of essential fish habitat in the review of projects conducted under Federal permits, licenses or other authorities that affect, or have the potential to affect such habitat." 

Sustainable Gulf of Mexico fisheries has declined, recovery of threatened or endangered species is not occurring, and the health of marine and anadromous fish habitats continues to degrade. Pollution of water resources, degradation of important marine habitats, and habitat loss continue at an unacceptable rate in the Gulf Coast states.  

Florida's coastline is home to hundreds of fish species.  In addition, these fish support commercial and recreational fishing industries that bring substantial revenues to the state and coastal communities. 

Fish resources and EFH will be impacted by coastal environmental degradation, marine environmental degradation, pipeline trenching, and offshore discharges of drilling discharges and produced waters associated with routine activities. 

Offshore Environmental Impacts

In addition to pipeline blowouts or leaks causing serious environmental problems, laying offshore pipes will cause increased turbidity of marine waters, destruction of seagrass beds and resuspension of contaminated sediments. Fish resources will be impacted by coastal and marine environmental degradation, pipeline trenching, and offshore drilling discharges associated with routine oil and gas drilling operations. 

Seismic surveys require the use of air guns, which use explosive blasts to map rock formations on the sea floor. Sound from these underwater blasts can be detected for thousands of miles.  Seismic testing can have profound, even fatal effects. 

Finally, as we have stated, previous oil and gas leasing Environmental Impact Statements for the OCS have been inadequate and if leasing is permitted to proceed, we fear there can be serious public health, economic, and environmental consequences above and beyond what is currently happening with the Deepwater Horizon oil spill, including damage to the tidal marshes, our coastal sea grasses, forested and non-forested wetlands, and mangroves.