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Post-Suspension Activities on Nine Federal Undeveloped Units and Lease OCS-409

Aspen prepared a multi-disciplinary Environmental Information Document (EID) and ten Coastal Consistency Determinations (CDs) for the U.S. Department of the Interior, Minerals Management Service (MMS).  The documents were prepared to address a suite of hypothetical oil and gas development scenarios of nine undeveloped “Units” and one undeveloped lease in federal waters offshore Ventura, Santa Barbara and San Luis Obispo Counties, California.  The documents were prepared for submittal to the California Coastal Commission for review under the Coastal Zone Management Act.

The EID included the preparation of comprehensive, resource/issue-specific “baseline” conditions, and identified the direct, indirect and cumulative impacts of the hypothetical development scenarios over a 24-year period from 2006 to 2030; these scenarios included the use of existing off- and onshore oil and gas infrastructure, as well as new infrastructure, including offshore platforms, off- to onshore pipelines, and onshore oil and gas processing facilities.  All phases of potential development were included in the evaluation, including construction, development and operation, and decommissioning.  Per concerns that had been submitted to the MMS by the California Coastal Commission and public interest groups, emphasis was placed on potential long-term cumulative impacts. Key technical areas of the EID included oil spill risk and movement, marine biological resources, recreation, visual resources, and non-residential land use and infrastructure.

Following preparation of the EID and a suite of Environmental Assessments prepared by the MMS for operator-specific “suspension phase” (pre-development) activities, Aspen completed a suite of policy analyses for project -specific consistency with the California Coastal Act.  In total, ten separate CDs were prepared, one for the each of the nine undeveloped Units and the one undeveloped lease. The evaluations addressed activities over a 25-year timeframe, from 2005 through 2030, and were focused on public access, recreation, the marine environment, land resources, general development, and industrial development. A unique aspect of the CDs was a requirement to address the proposed “suspension-phase” activities that required California Coastal Commission approval, as well as long-term (“post-suspension”) activities that were not formally proposed and did not require regulatory approval at the time of document preparation, but were included to provide a frame of reference for future actions that could be proposed.

Aspen prepared all draft and final documents within a very rapid timeframe to meet the MMS’s scheduling requirements for California Coastal Commission submittal.  Scheduling needs required “real-time” interaction and coordination betweenAspenand MMS staff throughout all project phases.  Additionally, due to the sensitive nature of offshore oil and gas development within the project area, Aspen worked closely with MMS staff to ensure that comments and concerns expressed by both the public and the California Coastal Commission were fully addressed in the documents, and that clear distinctions between current and future development phases and their associated regulatory review and approval requirements were made.  

Practice areas: Energy

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