is in an area where ill-considered action could defeat desired ends. The subject matter is interrelated to complexities of the ambulatory boundary problem which. as we have earlier suggested, is a matter that in itself, should receive the most careful expert attention. We recommend therefore, to this Committee that it take note of the need for legislation on this important problem now and the realization that such need will increase in the future. After technical studies, we have initiated are completed, Louisiana expects to come back to the Congress with specific recommendations and hopefully gain the concurrence of the administration on the proposals Louisiana will submit.

Question G-4. What should the role of the State government be with respect to Federal decision-making concerning:

Answer. (a) Exploration?: The States should have a very active role in Federal decision-making concerning exploration on OCS lands bordering the States' jurisdiction. In order to accomplish this, special policies should be developed by a joint State-Federal effort with regard to such matters as drilling regulations, the spacing or density of wells, production allowables, production handling and unitization procedures. Louisiana has long played a significant role in regulating seismic exploration in offshore areas. By agreement with the Department of the Interior, the State of Louisiana develops, promulgates and enforces all regulations to the edge of the OCS for the protection of fishing areas in Louisiana and on the OCS.

(b) Leasing?: The States should be informed about Federal leasing proposals and have the opportunity to approve or oppose the leasing of certain areas. There have been instances in Louisiana when agreements were worked out with the Federal Government whereby leasing and exploration in specific areas would be programmed so as not to interfere with peak shrimping seasons. These agreements were based on shrimp population dynamics research made available by the State. (c) Environmental regulations on OCS lands bordering the States' jurisdiction?: The States have what may be termed an overriding interest in Environmental regulations on OCS lands bordering the States' jurisdiction. The States are probably in a better position to either develop or evaluate environmental regulations in their coastal waters and on the adjoining OCS since, generally, they have a greater amount of scientific information on the local ecosystem. Because of this, we would strongly recommend that Environmental regulations developed for the OCS be thoroughly coordinated with and approved by the border states.

Question G-5. Are there high priority research or administrative programs related to OCS administration that remain unfunded, underfunded, or short of personnel?

Answer. Without question, a considerable amount of high priority research should be directed to determining the effects of chronic oil pollution and localized accidental spills. While present fishery production in Louisiana would indicate that serious toxic effects from oil do not occur, this question is still largely unanswered and must be answered before unlimited mineral exploration can be condoned throughout the ocean areas. Additional work is also needed to determine the effects of buried and unburied pipelines. At the present time, it appears that it will be very difficult to bury pipelines in water depths beyond the two hundred foot contour line. Thirdly, if dispersants or other types of chemical control of oil pollution is advocated, a considerable amount of bioassy work is needed to determine whether the toxicity of such chemicals alone or in combination with oil is more detrimental to the environment than oil alone.

Question I-2. In light of existing and projected demands for energy and the simultaneous requirements to protect the marine environment, what alternative sources of energy other than OCS petroleum from future leases are readily available and at what economic costs and environmental risks?

Answer. With regard to Louisiana, the most objective and far reaching method of obtaining alternative sources of energy, other than leasing of the OCS, would be increased onshore private exploration for oil and gas which should be encouraged by permitting a general rise in the price of crude oil which we consider depressed as compared with other products except natural gas. While such a price rise would obviously be eventually borne by the consumer, it offers a practical means of halting the declining rate of exploratory effort and encouraging additional drilling for onshore reserves that are badly needed.

Regarding natural gas, the greatest possible incentive to achieve accelerated exploration that could be given to the oil and gas industry and indirectly benefit

the consuming public would be to remove the FPC price restrictions entirely and let the price of gas seek its natural level. The renewed interest in exploratory drilling not only would result in substantially increased reserve of gas, but it would also increase oil production substantially. Again, the resulting cost increase to the consumer would more than be overcome by the insurance to them of a reliable and steady domestic supply of natural gas.

Question 1-3. What would be the economic, security of supply, and environmental consequences of alternative strategies for the scheduling of OCS resource development (e.g. postponing development and consumption of these resources until the need for them is greater, due to increased costs or unavailability of imported oil)?

Answer. The postponing of development and subsequent non-consumption of optimistically assumed resource reserves, until such time as imported oil becomes unavailable or the cost of such oil becomes prohibitive would be impractical for several reasons:

(1) The United States would be at the mercy of unfriendly powers in the Middle East and Africa where more than 75% of the known world reserves of oil are located.

(2) Technical and professional personnel and operational equipment would be lost to foreign operations or assimilated into other industries thus destroying the domestic oil and gas industry. This would have a catastrophic effect on the economy. Once this nation postpones development and the domestic industry loses the expert and skilled labor force and the necessary drilling equipment to other nations, it would be virtually impossible to again start up the industry, and the leadtime that has been developed over the years will have vanished forever.

(3) Training centers would be lost and educational endeavors curtailed. (4) Research would virtually terminate.

(5) National security would be endangered as no immediate source of energy would be available in the event imports should suddenly cease. As an illustration, the country as a whole was unable to meet the demands placed upon it by withdrawal of Eastern Hemisphere oil during the Suez Canal crisis in 1956. What shutin capacity we had at that time has largely disappeared in the intervening 16 years. Today's shut-in capacity is insignificant. National security demands that domestic sources be developed to the greatest extent possible.

(6) Environmental damage or oil spill pollution would still be a major concern due to the tremendous amount of imported oil being brought in by large tankers. It is imperative that an orderly development onshore and offshore continue at least until such time in the future as alternative sources of energy, such as nuclear or solar, can be economically generated.

Question J-1. What are the nature and magnitude of environmental risks and problems related to OCS oil and gas development in:

Answer. (a) Geophysical exploration: Historically, geophysical exploration has been accomplished through recordings of refracted sound vibrations derived from under-water explosions. The detrimental effects to the environment as well as the flora and fauna are apparent. We realize that a series of underwater explosions in the Gulf of Mexico is probably insignificant when compared to natural disasters, but it is very possible that these shock waves disrupt the spawning of some of our commercially important species. The impact of such a catastrophe on the states' economy would be incalculated and not worth the risk, since alternate methods appear available.

Recent innovations of seismic instrumentation and exploration indicate that seismic profiling can be accomplished utilizing a much less destructive sound source. Seismic exploration should be limited to these alternate sources.

(b) Drilling and Production: All of the environmental risks involved with drilling and production are not known since the taxic effect of oil in the ecosystem is not clear. However, several problems that may be of immense magnitude to the environmental are recognized:

Accidental and Chronic Pollution

Accidental pollution can be disastrous, costly, create great public concern, and cause spectacular short-term local environmental disruption. Conclusions that may be drawn concerning the effects of accidental pollution include the following: 1. There is little or no evidence that accidental oil pollution has a gross permanent effect on the ecosystem. Whether minor or accumulative effects occur have not been demonstrated.

2. Even when loss of animal or plant life occurs, in time, recovery of the environment is followed by return of normal populations. In most cases the recovery time is not prolonged.

3. The principal problems resulting from accidental oil spills involve these factors:

(a) Contamination of filter-feeding animals.

(b) Heavy fouling of beach or marsh areas; and the coating of birds, animals and plants in local areas.

(c) Fouling of private property and the cost of cleanup procedures. Chronic pollution by contrast, is a more critical and less understood problem. Prior to increased state regulation and surveillance of the oil industry continuing lowlevel pollution associated with intensive oil production in shallow inshore embayments and marsh areas was common in Louisiana. Production from numerous wellheads, with associated gathering lines, tank batteries, separators and sludge pits all afford opportunity for leaks and spills causing chronic introduction of oil into the ecosystem. There were areas of intensive petroleum production where chronic oil loss had ruled out other uses of the area, destroying once valuable oyster reefs and shrimping grounds. However, the onset of stricter state safety regulations as well as company initiated safety precautions have led to the installation of additional safety equipment and oil spills have been kept to a minimum in recent times. It has been our experience that oil and gas operations can be conducted with only minimal interference to other users of our bays, marshes and offshore areas and there is no reason to believe the OCS cannot enjoy the same multiple uses.

Oil Emulsion Muds

One of the most serious and long-lasting types of pollution associated with the petroleum industry occurs when diesel oil is added to the mud system to enhance the drilling of deep wells. If the excess or used mud or cuttings from such an operation is lost overboard, there results a serious oil pollution of the substrate since the oil is absorbed into the heavy mud particles and settles to the bottom. Visible oil slicks may not occur and the pollution may go undetected. If oysters or other filter-feeding animals are in the area, they soon filter out and concentrate the oil and develop an unpalatable oily taste. As little as five hundred parts per million of oil in mud will cause serious problems in oysters and even one part per million added to a running-water system will be concentrated by oysters kept in the system for several weeks.

Detergents, Dispersants and Other Chemicals Used to Clean Up Oil Spills

Usually when oil spills occur, public outcry and concern on the part of the industry to reestablish good public relations result in rapid and costly attempts to clean up the area or to make the visible oil disappear from sight. From our experience with oil emulsion muds, this may be the worst approach possible to the cleanup problem for these reasons:

1. Detergents or dispersant chemicals may cause the oil to absorb on mud and silt particles which sink to the substrate or float in the water column where they are more available to filter feeders.

2. Absorbed oil on the bottom particles appears to take longer to degrade.

3. The use of chemicals to disperse the oil involves placing an additional load of foreign and undesirable material in the ecosystem. Many of the dispersants tested proved to be far more toxic than oil.

4. Dispersal of oil does not allow proper mapping or study of polluted areas. 5. Floating oil is probably the least damaging position for oil to occur in the ecosystem. Here it degrades more rapidly-its only effect is at the interface and, except in intertidal areas and marshes, will usually dissipate, degrade and be mechanically dispersed by wave action with little apparent effect on the ecosystem.

Commercial Fishery Problems

Offshore operations have created several types of problems for commercial fishermen, particularly shrimp trawlers. The principal difficulties for fishing fleets involve navigational problems and seabed obstructions. The producing platforms and other above-water structures are well marked and lighted but when they become extremely numerous, significant fishing area is lost. Occasionally boats collide with structures but the primary problem seems to be that, with

fishing gear down, they must stay well clear of the rig in order to avoid possible collision or the entanglement of gear in underwater material discarded from the rig. This means that a considerable area around each site cannot be safely fished and significant fishing area may be lost to them.

Until recently underwater completions and inactive stubs were a serious problem. These obstructions, if in water greater than eight feet above their highest point, do not have to be marked or bouyed. More than two hundred such structures clutter the sea floor off Louisiana and this has resulted in the loss of a considerable amount of expensive fishing gear. New rule changes now allow the pipes to be cut off below the mudline and it is expected that most of these hazards will be removed within the next year or two.

(c) Undersea pipeline construction and operation.—Undersea pipeline construction and operation is not a serious environmental problem if regulated to prevent exposed pipes on the seabed. Usually subsurface currents will alleviate the problem by burying pipelines. New construction is a potential hazard to commercial fishermen and has resulted in gear loss.

(d) Tanker operation. The overall damage from a tanker spill is probably minimal if it occurs offshore and remains away from the coastal marshes. With the advent of super-oil tanker ports which will concentrate these large vessels in a near offshore area, the possibility of vast oil spills, constant leakage, and accumulation of minor spills is tremendously enhanced and this poses a great threat to the environment in these areas unless closely regulated.

(e) Onshore pipeline construction and operation.-Highest priority should be afforded to the prevention of alteration of the environment in inshore pipeline construction and operation. Some of the related problems are:

1. The dredging and channelization needed for the navigation of drilling rigs to location result in direct destruction and loss of nursery areas from dredging, silting, leveeing and erosion. Sessile animals and bottom organisms are killed or dislocated while marsh areas may be destroyed, drained and drastically altered.

2. Pipeline construction can be especially destructive and result in serious ecological changes. The construction of large and long pipelines requires the dredging of wide and deep flotation canals for the laying equipment. These canals, 40 or more feet in width traverse and cut through marshlands and embayments without regard for changes in the natural drainage pattern, the disruption of currents in bays or waterflow in marshlands, and the direct loss of animals and plants within the rights-of-way from dredging and silting. Long-range effects involve serious erosion of unstable marshes traversed by such canals.

3. Even in cases when dredging is not a factor, shorelines, intertidal areas, marshes and very shallow waters which make up an important part of the ecosystem can be cut up and destroyed by vehicular traffic such as mudboats, marsh buggies, tugs and equipment barges and other heavy equipment.

4. More widespread and serious ecological damage and disturbance of the ecosystem occur from the indirect and secondary effects of the above activities. The more direct effects are local in nature and are generally in or near the rightsof-way while the indirect effects are more far-reaching and difficult to evaluate. These include: (a) Changes in water cycling rates and volumes: (b) Sale and freshwater intrusion; (c) Indirect silting considerable distances from the site of activity resulting from changes in the direction and velocity of currents; (d) Partial or total disruption of normal drainage patterns and water movements.

Question J-5. What quantative information is available about the total costs of past mishaps on the OCS, including oil and gas lost, private and government cleanup costs, loss of fish and wildlife, damage to tourism, reduced property values, and administrative costs?

Answer. Losses to fish and wildlife in the Louisiana area has not been demonstrable nor has any data been presented which statistically supports evidence of economic losses. The administrative costs to the State of Louisiana for surveillance, research and additional workload during times of serious accidents has been considerable, probably exceeding several hundred thousand dollars per accident.

Question J-7. What additional geological, biological, engineering or other information is necessary with regard to improving the environmental safety aspects of offshore oil and gas operations? Is there research that ought to be completed before any further offshore leasing? Are there specific instances or areas in which

leasing should be postponed pending completion of further studies? What time, effort and costs would be involved in this research?

Answer. We are of the opinion the studies that have been completed and the environmental safety aspects presently required through Federal OCS rules and regulations are sufficient. The State would continue to cooperate and encourage new and improved safety devices, where reasonable, in order to further protect the environment. Leasing, exploration and development should not be postponed to await completion of research projects or studies.

Ouestion K-2. Should the Congress determine, on a case by case basis, the circumstances under which tracts of OCS lands should be established as marine preserves or sanctuaries?

Answer. Whether established by Congress, or other authority, we agree that these must be considered on a case by case basis. However, any establishment of a marine preserve or sanctuary should be considered under the multiple land usage concept which includes petroleum exploration and development. The State of Louisiana has years of experience, which has been documented, in the exploration and development for oil and gas associated with preserves or sanctuaries. Under the specific rules and regulations established for similar State areas, multiple use has, does and can exist. Prime examples of these are: (1) Avery Island Bird Sanctuary and Scenic Gardens, (2) Pass-a-Loutre Game and Fish Preserve, (3) Rockefeller Wild Life Refuge and Game Preserve and (4) Russell Sage or Marsh Island Wild Life Refuge and Game Preserve.

Question K-3. Are there instances in which highly promising OCS acreage should be permanently reserved from development for recreational, ecological, or aesthetic reasons? What cost-benefit standards should be applied to proposals for reservations of this type? What other standards or considerations should be applied to proposals for reservations of this type?

Answer. We feel reasonably certain that some areas should be set aside for permanent recreational and ecological reasons. Many such areas could probably be located in areas where mineral production does not occur. A real problem does exist in Louisiana where vast mineral resources underlie a unique and extremely valuable fishing area. Setting aside this area for the fishery purposes along probably could not be justified in view of the tremendous oil reserves involved. However, if the fishery and natural resources production of the Louisiana coast is destroyed because of mineral production, the long-term economic loss to the country would be staggering and the loss of food and nutrients to a growing human population would be incalcuable. In view of this, exceedingly careful regulation of the area should be undertaken and probably some cutoff point in mineral exploitation should be determined beyond which this highly productive area would not be subjected to further ecological dangers. This problem, however, really lies in the nursery grounds and coastal areas well within Louisiana's jurisdiction and does not constitute a major problem on the outer continental shelf.

Question K-5. If a short term (two-year) or long term (five- to ten-year) moratorium were established and all OCS operations were suspended:

(a) From what probable alternative sources would petroleum demand be filled?

Answer. For the short term (two-year), we see no alternative source for petroleum demand except from foreign sources. The lead time to develop new resources in this country varies from five to seven years for conventional fuels. The same answer would prevail for the long term (five- to ten-year). The lead time for developing other forms of energy as alternatives, the so-called exotics, would require from 10 to 20 years.

(b) To what extent, if any, would these alternatives reduce the risk of coastline oil pollution?

Answer. The only alternative, as indicated in the answer to K-5 (a) above, is increased use of foreign oil. Rather than reduce the risk of coastline pollution. we believe the risk would be increased. Statistics are available which indicate that tanker leakage and spillage from accidents on the high seas cause a major portion of coastline pollution. If more foreign oil is transported to our shores by tankers, then we believe the risk would be materially increased.

(c) What new environmental risks would be associated with alternative sources of supply?

Answer. The answer to K-5 (b) we believe also answers this question. We know of no new risks. The risks would only change in location.

Question E-1. What is the procedure currently used by the State (Federal) agencies for determining, on a short range (one year), intermediate range (five years), and long range (five years and beyond) basis: