United States Fish and Wildlife Service Delta National Wildlife Refuge Plaquemines Parish, Louisiana

Matrix New World Engineering, Land Surveying and Landscape Architecture, P.C. 2798 O’Neal Lane, Building F Baton Rouge, LA 70816 www.matrixneworld.com

Matrix Project No. 18-1083

May 2019

Section Page 1.0 PURPOSE AND NEED FOR THE PROPOSED ACTION ...... 1 2.0 ALTERNATIVES CONSIDERED ...... 2 2.1 No Action Alternative ...... 2 2.2 Alternate Well Pad Locations ...... 2 2.2.1 Delta Duck Well Prospect No. 1 - Alternate ...... 2 2.2.2 Proposed Delta Duck Well Prospect No. 2 ...... 3 2.3 Alternate Flow Line Routes ...... 3 2.3.1 Alternate Flow Line Route A ...... 4 2.3.2 Alternate Flow Line Route B ...... 4 2.3.3 Alternate Flow Line Route C ...... 4 2.3.4 Alternate Flow Line Route D ...... 4 2.3.5 Alternate Flow Line Route E ...... 4 2.3.6 Alternate Flow Line Route F ...... 5 2.3.7 Alternate Flow Line Route G ...... 5 2.4 Proposed Alternative ...... 5 3.0 AFFECTED ENVIRONMENT ...... 8 4.0 ENVIRONMENTAL CONSEQUENCES OF THE ACTION ...... 9 4.1 Cumulative Impact Analysis ...... 33 5.0 CONSULTATION AND COORDINATION ...... 35 5.1 List of Sources, Agencies and Persons Consulted: ...... 35 5.2 Consultation with Tribal Nations ...... 35 6.0 REFERENCES ...... 35 6.1 List of Preparers ...... 38 6.2 Public Outreach ...... 38 6.3 Determination ...... 38

18-1083 Delta Duck Well Prospect No. 2 EA i

Figure Title 1 Site Location Map 2a-2g Alternate Routes 3 Delta National Wildlife Refuge & Proposed Work Areas 4 Delta and Brenton National Wildlife Refuges

Appendix Title A Farmout Agreement B Special Use Permit Application (Drilling) C Coastal Drilling Company Rig-20 Inventory D Coastal Drilling Company’s SPCC Plan E TPIC’s Emergency Response Plan F SHPO Consultation Concurrence G USFWS Consultation Concurrence H THPO Responses I Other Applicable Statutes, Analysis or Permits Used to Complete EA or Process Permit J Field Inspections, Other Studies, Analysis or Permits Used to Complete EA or Processing Permit

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18-1083 Delta Duck Well Prospect No. 2 EA Date: May 10, 2019

Permit Application Information

Applicant Name: LLOX, L.L.C. (LLOX)

Company Contact: Ron Harvey, Operations Manager

Operations Location: 1001 Oschner Blvd., Suite A, Covington, LA 70433

Preparer: Delta National Wildlife Refuge and U.S. Fish and Wildlife Service National Energy Team

Consultant: Matrix New World Engineering, Land Surveying, and Landscape Architecture, P.C.

Direct Comments To: Delta National Wildlife Refuge, 61389 Hwy 434, Lacombe, LA 70445 c/o Refuge Manager, Jimmy Laurent

The purpose for the proposed action is to respond to a request by LLOX (Applicant) for an Operations Permit (Permit) for Applicant’s proposed activities of drilling the Delta Duck Prospect well. As required by 50 CFR §29.94(b), the Applicant has filed with Delta National Wildlife Refuge (NWR or Refuge) documentation demonstrating that it holds the legal right to conduct the proposed operations (Appendix A). This proposed action is needed to ensure that mineral rights holders have reasonable access to develop their non-Federal oil and gas interests and minimize impacts to Refuge resources to the extent practicable under the Service’s 50 CFR Part 29, Subpart D regulations (29D Regulations) for managing non-Federal oil and gas on Service-administered lands and waters. The purposes of implementing these regulations are:

1. Protecting Service-administered lands and waters, and resources of the refuge; 2. Protecting refuge wildlife-dependent recreational uses and experiences, and visitor and employee health and safety; 3. Conserving the Refuge for the benefit of present and future generations of Americans; and 4. Implementing technologically feasible and least damaging methods for oil and gas activities on the Refuge. These methods are determined on a case-by-case basis to protect refuge resources and uses, while ensuring human health and safety. The determination will take all relevant factors into consideration, including environmental, economic, and technological factors and the requirements of applicablelaw.

18-1083 Delta Duck Well Prospect No. 2 EA 1 As the Applicant’s proposed actions are not in sensitive habitat, but rather in an area already highly impacted by non-Federal oil and gas activity, there is no conflict with respect to alternative uses of the resources in this area, so the Environmental Assessment (EA) does not need to consider additional alternatives (43 CFR 46.310 (b)). However, during the initial planning stages of the proposed action the Applicant assessed a broader range of alternatives to facilitate planning and decision making (43 CFR 46.310 (c)). In addition to the “No Action Alternative”, two (2) well pad locations and seven (7) alternative flow line routes were assessed prior to selecting the proposed alternative. The alternative well pad location and six (6) alternate flow line routes are depicted on Figure 1, as well as the proposed well pad and flow line route.

Under the No Action Alternative, the United States Fish and Wildlife Service (Service) would not engage the Applicant in a permitting process. However, the Applicant has the legal right to access their minerals beneath the refuge surface regardless of a permit. Therefore, bypassing the permitting process will result in the Applicant accessing their minerals without being required to comply with the 29D Regulations, and there will be no assurance that the Applicant would use technologically feasible and least damaging methods.

The Applicant assessed a surface location centered at approximate Latitude 29.241376° and Longitude - 89.155912° in Section 33, Township 20 South, Range 20 East of Plaquemines Parish, Louisiana. Access to the location utilized the Mississippi River at Main Pass to Octave Pass, thence to Buoy Pass into Dead Women Pass, terminating at the location in Dead Women Outside Pond. Water depths from the Mississippi River to approximate Latitude 29.238889° and Longitude -89.164167°, in Dead Women Pass, averaged eight (8) to twelve (12) feet deep resulting in no adverse impacts by prop-washing from equipment access. From approximate Latitude 29.238889° and Longitude -89.164167°, in Dead Women Pass, to the well pad location water depths decreased, resulting in approximately 1,933-feet-long by 73-feet-wide area of prop- washing with an average cut of 1.5 feet (7,505 yd3, 3.1 acres impacted). Additionally, to site the drill barge, the well pad slip required approximately 645-feet-long by 160-feet-wide area of prop-washing with an average cut of 4.5 feet (13,315 yd3, 1.8 acres impacted). Adverse impacts associated with Delta Duck Prospect No. 1 totaled 4.9 acres of water bottoms (20,820 yd3).

18-1083 Delta Duck Well Prospect No. 2 EA 2

The Applicant assessed a surface location centered at approximate Latitude 29.23333° and Longitude - 89.162500° in Section 4, Township 21 South, Range 20 East of Plaquemines Parish, Louisiana. Access to the location utilized the Mississippi River at Main Pass to Octave Pass, thence to Buoy Pass into unnamed tributary, terminating at the location in Dead Women Inside Pond. Water depths from the Mississippi River to the well pad slip, averaged eight (8) to twelve (12) feet deep resulting in no adverse impacts by prop- washing from equipment access. To site the drill barge, the well pad slip required approximately 435-feet- long by 160-feet-wide area of prop-washing with an average cut of 1.5 feet (3,642 yd3, 1.5 acres impacted). Adverse impacts associated with Delta Duck Prospect No. 2 totaled 1.5 acres of water bottoms (3,642 yd3) and thus was chosen as the preferred (proposed) alternate. For reference Delta Duck Well Prospect No. 2 (discussed here in) is identified on the enclosed permit plats as Delta Duck Location “B” Prospects.

The Applicant assessed seven (7) alternatives for the proposed two, six-inch flow lines to serve the proposed Delta Duck Well Prospect No. 2. All seven alternatives consisted of approximately 8,443 feet of dual, four- inch-diameter flow lines connecting the Delta Duck Well Prospect No. 2 to Texas Petroleum Investment Company’s (TPIC) existing DDC Well U2 No. 161, centered at approximate Latitude 29.223133° and Longitude -89.179818°, 1.25 miles southwest of the proposed well locations in Section 8, Township 21 South, Range 20 East of Plaquemines Parish, Louisiana. The construction of the proposed flow lines interconnecting the Delta Duck Well Prospect No. 2 to TPIC’s existing DDC Well U2 No. 16 (TPIC Well), will be installed via jetting, through Goose Island Inside Pass, approximately 4.3’ below the mudline. Water bottom impacts as a result of the jetted flow line ditch (8,443 linear feet of the dual 4” flowlines) are approximately 5,416 yd3 (0.78 acre). The alignment of this interconnect is depicted on Figure 2a through 2g as a dashed, black line. The alternates assessed incorporate flow line routes from either the Delta Duck Well Prospect No. 2 or existing DDC Well U2 No. 16 to TPIC’s existing production facility2 (Delta Duck Central Facility) centered at approximate Latitude 29.245297° and Longitude -89.199786°, 2.40 miles northwest of the proposed well locations in Section 31, Township 20 South, Range 20 East of Plaquemines Parish, Louisiana. Identified on Figure 1 as “Existing TPIC Facility”. Two alternates (2a and 2g) share approximately 2,545 linear feet of the interconnecting flowline alignment and water bottom impacts (1,652 yd3) for theses alternates are calculated as such. Upon completion of the proposed Delta Duck Well Prospect No. 2 and installation of the dual, four-inch- diameter flowlines and dual six-inch-diameter flowlines, LLOX intends to turn over the operation of the well(s) and flow lines to TPIC.

1 TPIC’s DDC U2 No. 16 was previously authorized by Louisiana Department of Natural Resources permit number P20110532. 2 TPIC’s existing production facility was constructed prior to Louisiana Department of Natural Resources, Coastal Management regulation.

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Alternate A consists of approximately 17,041 feet of dual, six-inch-diameter flow lines installed from the proposed Delta Duck Prospect No. 2 west through Buoy Pass, south through Octave Pass, thence north through Octave Pond to the Delta Duck Central Facility. Alternate A would be installed via jetting to a depth of 4.5’ below the mudline. In addition to the 0.23-acre impacts (1,652 yd3) of the of shared alignment with the interconnecting flowlines, water bottom impacts as a result of the jetted flow line ditch are approximately 11,361 yd3 (1.56 acres). The alignment of Alternate A is depicted on Figure 2a.

Alternate B consists of approximately 21,680 feet of dual, six-inch-diameter flow lines installed from TPIC’s existing DDC Well U2 No. 16, south through Twentyseven Pass, thence north through Octave Pass, then commences west, entering Octave Pond, north to the Delta Duck Central Facility. Alternate B would be installed via jetting to a depth of 4.5’ below the mudline. Water bottom impacts as a result of the jetted flow line ditch are approximately 14,453 yd3 (1.99 acres). The alignment of Alternate B is depicted on Figure 2b.

Alternate C consists of approximately 22,019 feet of dual, six-inch-diameter flow lines installed from TPIC’s existing DDC Well U2 No. 16, south through Twentyseven Pass, thence north through Octave Pass, then commences west, entering Paul Pond, turns north in Paul Pond, then commences east into Octave Pond, north to the Delta Duck Central Facility. Alternate C would be installed via jetting to a depth of 4.5’ below the mudline. Water bottom impacts as a result of the jetted flow line ditch are approximately 14,679 yd3 (2.02 acres). The alignment of Alternate C is depicted on Figure 2c.

Alternate D consists of approximately 30,880 feet of dual, six-inch-diameter flow lines installed from TPIC’s existing DDC Well U2 No. 16, south through Twentyseven Pass, thence north through Octave Pass, then commences west, in an unnamed tributary of Octave Pass, and south to the Delta Duck Central Facility. Alternate D would be installed via jetting to a depth of 4.5’ feet below the mudline. Water bottom impacts as a result of the jetted flow line ditch are approximately 20,587 yd3 (2.84 acres). The alignment of Alternate D is depicted on Figure 2d.

Alternate E consists of approximately 29,490 feet of dual, six-inch-diameter flow lines installed from

18-1083 Delta Duck Well Prospect No. 2 EA 4

TPIC’s existing DDC Well U2 No. 16, south through Twentyseven Pass, thence north through Octave Pass, then commences west, entering Octave Pond, thence commences east into Post Pond, turns north through Cane Pond, thence west in an unnamed tributary of Octave Pass, and south to the Delta Duck Central Facility. Alternate E would be installed via jetting to a depth of 4.5’ feet below the mudline. Water bottom impacts as a result of the jetted flow line ditch are approximately 19,660 yd3 (2.71 acres). The alignment of Alternate E is depicted on Figure 2e.

Alternate F consists of approximately 24,560 feet of dual, six-inch-diameter flow lines installed from TPIC’s existing DDC Well U2 No. 16, south through Twentyseven Pass, thence north through Octave Pass, then commences west, entering Octave Pond, thence commences northeast through Tilitie Pond, thence west in an unnamed tributary of Octave Pass, and south to the Delta Duck Central Facility. Alternate F would be installed via jetting to a depth of 4.5’ feet below the mudline. Water bottom impacts as a result of the jetted flow line ditch are approximately 16,373 yd3 (2.26 acres). The alignment of Alternate F is depicted on Figure 2f.

Alternate G consists of approximately 15,085 feet of dual, six-inch-diameter flow lines installed from the proposed Delta Duck Well Prospect No. 2, then west through Buoy Pass, turns north in Octave Pass, thence west in an unnamed tributary of Octave Pass, and south to the Delta Duck Central Facility. Alternate G would be installed via jetting to a depth of 4.5’ feet below the mudline. In addition to the 0.23-acre impacts (1,652 yd3) of the 2,545-foot-long shared alignment with the interconnecting flowlines, water bottom impacts as a result of the jetted flow line ditch are approximately 10,057 yd3 (1.39 acres). The alignment of this Alternate G is depicted on Figure 2g.

Cumulative adverse impacts associated with Alternate G and the interconnect associated with all seven alternatives totals 2.39 acres of water bottoms (17,125 yd3) and thus was chosen as the preferred (proposed) flow line alternate.

The Service has received an application (Appendix B) for a permit for proposed oil and gas operations on the Refuge incorporating Delta Duck Well Prospect No. 2 and Alternate Flow Line Route G, discussed above. The proposed action is for the Refuge to issue a permit to the Applicant. The Applicant has demonstrated that through ownership of oil and gas rights, they have the right to access and develop oil and gas resources underneath the Refuge. Therefore, the action being considered is not whether or not to allow this operation to proceed, as it is the Applicant’s right to access and develop these resources, but rather to

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ensure that the Applicant avoids or minimizes impacts from such activities to the maximum extent practicable. Therefore, the Service is proposing to issue a Permit that ensures that the Applicant is using the most technologically feasible, least damaging methods to conduct operations on the Refuge in accordance with 50 CFR Part 29, Subpart D.

1. The Applicant proposes prop-washing a calculated 3,642 yd3 of water bottoms (1.5 acres), to site the drill barge on the proposed well pad slip. No prop-washing will be required for equipment access to the drilling location. 2. Navigating a drilling barge to the proposed well location via existing access canals and passes. 3. Drilling the Delta Duck Well Prospect No. 2 4. Upon successful completion of the well(s), the applicant proposes jetting a calculated 5,416 yd3 of water bottoms to install approximately 8,443 feet of dual, four-inch-diameter flow lines (0.78 acres) between the well and an existing TPIC Well, and jetting an additional calculated 10,057 yd3 of water bottoms to install approximately 17,630 feet of dual, six-inch diameter flowlines (Alternate Flow Line Route G) between the well and the existing TPIC Delta Duck Central Facility (1.39 acres). The applicant proposes the jetting of a calculated total of 17,105 yd3 of water bottoms (2.39 acres) to install flowlines. 5. Turning over the production and maintenance to TPIC for the foreseeable future.

For a list of equipment proposed to be used by operator, see Coastal Drilling Company RIG-20 Inventory (Appendix C).

The 29D regulations Operations Permit application was determined to be complete, in accordance with 50 CFR §29.101 and is incorporated into this EA by reference (Appendix B).

In order for the Applicant to comply with the Service’s standards and ensure operations are the most technologically feasible and least damaging methods, the Applicant has proposed to utilize the following methods to avoid or minimize impacts of their proposed drilling operation:

• LLOX will contract a drilling barge that is equipped for full zero discharge operations for work within environmentally sensitive areas. This would include peripheral coamings completely enclosing appropriate deck areas to contain any spills of hazardous materials that might occur. The contracted drilling barge would operate under its own Spill Preventions, Containment, and Countermeasure (SPCC) plan meeting all requirements of 40 CFR 112. • LLOX has proposed a drilling site in an open water pond, thus minimizing disturbance to marsh habitat. LLOX has proposed to install 26,073 feet of new flow line by jetting unvegetated water bottoms, so that no new disturbance to marsh habitat would occur due to flow line installation.

In order for the Applicant to comply with the Service’s standards and ensure operations are the most technologically feasible and least damaging methods, the Service has proposed the Permit as follows:

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1. All work must be completed in accordance with the attached Special Use Permit (and associated conditions), Permit Plats, and these special use permit conditions. 2. The Special Use Permit and Permit Plats must be attached to this operations permit at all times and a copy must be aboard each vessel used to complete the work. 3. Access to perform work is only permitted on the routes indicated in the Permit Plats. 4. Once issued, the permit will be valid through October 31, 2020. A permit extension may be requested by the applicant if deemed necessary. 5. The permittee shall notify the Oil and Gas Specialist and/or Refuge Manager 48 hours prior to entering the refuge to obtain approval for specific dates of operation. 6. Failure to notify refuge staff, or any deviation from the work plan or specified access routes, may subject the Applicant to monetary fines and/or void the permit. 7. Personnel and equipment may remain on the Refuge overnight and conduct operations 24 hours per day. 8. When performing oil and gas related work the permittee shall comply with applicable General Terms and Conditions of 50 CFR, 29.120 and 121, and all applicable state and federal laws and regulations. 9. Permittee will use engines that adhere to applicable Federal and State emission standards. 10. Vessels and work zones are required to have refuse containers for the disposal of daily trash. All refuse and equipment shall be removed from the refuge at the end of this permitted operation. 11. The littering, disposing, or dumping in any manner of garbage, refuse, sewage, sludge, earth, rocks, or other debris on any national wildlife refuge, except at locations designated by the refuge manager, is prohibited. Furthermore, the draining or dumping of oil, acids, pesticide wastes, poisons, or any other types of chemical wastes; or otherwise polluting any waters or other areas within any national wildlife refuge is prohibited. 12. Persons possessing, transporting or carrying firearms on national wildlife refuges must comply with all provisions of State and local law. Discharging firearms is prohibited on the refuge except within permitted hunting zones and seasons, and in accordance with refuge regulations. (50 CFR 27.42 and specific refuge regulations in 50 CFR Part 32). 13. Killing, harassing, disturbing, injuring, spearing, poisoning, destroying, collecting or attempting to kill, harass, disturb, injure, spear, poison, destroy or collect any plant or animal on any national wildlife refuge is prohibited. 14. The permittee will keep disturbance to fish, wildlife, vegetation, and the environment to an absolute minimum. Feeding wildlife is prohibited. 15. Permittee will meet all Federal and State requirements for noise suppression while operating on the refuge. 16. The drilling rig will have inward facing lighting, pointing down; minimizing negative effects of spill lighting on night sky or surrounding habitat. 17. Permittee will post “warning/safety” signs at public access points (canals) surrounding drill rig. Warning public of increased boat traffic and operations.

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18. The failure of the United States or the Service to require strict performance of the terms, conditions, covenants, agreements, or stipulations of the permit, in the exercise of the permittee’s mineral rights on Refuge lands will not constitute a waiver or relinquishment of the right of the United States to strictly enforce thereafter such terms, conditions, covenants, agreements or stipulations which shall, at all times, continue in full force and effect. 19. The permittee will save, hold harmless, defend, and indemnify the United States of America, its agents and employees for loses, damages, or judgements, and expenses on a bodily injury, death, or property of any nature whatsoever, and by whomsoever made, arising out of the actions, or failure to act, by the permittee, its employees, contractors, subcontractors or agents with respect to the exercise of permittee’s mineral rights on the refuge. 20. All Refuge regulations will be enforced, and the permittee shall follow all applicable laws and regulations. The permittee is responsible for the actions of all employees, contractors, and support personnel. A complete list of regulations can be found in the “Code Of Federal Regulations, Title 50 – Wildlife and Fisheries” at: http://www.ecfr.gov/cgi-bin/text- idx?SID=d9d36ddafb7f99bcf8519c88286bb5ed&mc=true&tpl=/ecfrbrowse/Title50/50tab_02.tpl

Throughout the impact evaluation below, we have contrasted the impacts of the proposed action alternative of the Service with the current condition and expected future condition under the No Action Alternative.

This section describes the existing environmental and socioeconomic setting in the action area.

Delta Migratory Waterfowl Refuge was established by Executive Order No. 7229 on November 19, 1935, under the authority of the Migratory Bird Conservation Act. The initial acres forming Delta NWR were purchased from Joseph Leiter and the Delta Duck Club in 1935 to provide sanctuary and habitat for wintering and migrating waterfowl. The name was changed from Delta Migratory Waterfowl Refuge to Delta National Wildlife Refuge in 1940. Subsequent land purchases enlarged the Refuge to its current acreage of 48,799. (Figure 2).

Delta NWR is located on the east bank of the Mississippi River about 70 miles southeast of New Orleans in Plaquemines Parish, Louisiana (Figure 3). The Refuge encompasses a variety of habitats from freshwater marsh to sandy beach, and marine environments. It lies at the southern terminus of the Mississippi Flyway and provides important breeding, stopover, wintering, and year-round habitat for a variety of birds and other species of conservation concern.

Delta NWR has experienced oil and gas activities since the 1940’s. These include the full gamut of activities including exploration, development, production, and transportation pipelines. Over 400 oil/gas wells, 3 production facilities, countless miles of flowlines, miles of dredged canals, and over 50 miles of pipeline right-of-way (ROW) have been constructed/placed on the Refuge lands.

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Delta NWR is not located near any urban centers; the closest town is Venice, which is across the Mississippi River from actual Refuge lands. The Refuge is in Plaquemines Parish, Louisiana’s most southern parish, where the Mississippi River meets the Gulf of Mexico. There are no incorporated communities anywhere within the parish. The parish is bisected by the Mississippi River. Most of the population is distributed along a narrow band of land on each bank of the river. Sources of income include the seafood industry, the off-shore oil industry, shipping, and citrus groves. Millions of pounds of shrimp, oysters, crab, and fish are produced annually by the commercial fishing industry. The parish is also considered a “sportsman’s paradise” for sport fishing.

Encompassing seventy miles of the Mississippi River, Plaquemines Parish is the eighth largest port in the United States and is noted for exporting coal, petro-chemicals, and grain. In 2005, the parish population was 28,995 and the 2003 median income was $38,173 for a household. In August 2005, the entire parish was devastated by Hurricane Katrina which caused extensive structural damages and flooding, major losses to the commercial fishing industry, and a substantial decrease in population due to post-storm emigration. Residents are slowly returning to the parish as housing and other infrastructure are repaired or replaced, but major questions remain about levee protection and the viability of local communities.

The requested area of operations is within the Delta Duck Field which is located between Main Pass and Raphael Pass on Delta NWR, and primarily consists of fresh to intermediate marsh.

The tables below provide additional, brief descriptions of each affected resource.

For more information regarding the affected environment, please see Delta and Breton National Wildlife Refuge’s Comprehensive Conservation Plan and Environmental Assessment (https://www.fws.gov/southeast/planning/PDFdocuments/Delta%20Breton%20Final/DeltaBretonFinalCC Pdoc. pdf) , as well as the Habitat Management Plan for Delta and Breton National Wildlife Refuges (https://catalog.data.gov/dataset/habitat-management-plan-for-delta-and-breton-national-wildlife-refuges).

This section analyzes the environmental consequences of the action on each affected resource, including direct and indirect effects.

Direct effects are those which are caused by the action and occur at the same time and place.

Indirect effects are those which are caused by the action and are later in time or farther removed in distance but are still reasonably foreseeable.

Effects include ecological (such as the effects on natural resources and on the components, structures, and functioning of affected ecosystems), aesthetic, historic, cultural, economic, social, or health, whether direct, indirect, or cumulative. Effects may also include those from various actions, which may have resulted in

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both beneficial and detrimental effects, even if on balance the agency believes that the effect will be beneficial.

The tables below provide the following:

1. A brief description of the affected resources in the area of operations; 2. Typical impacts of oil and gas extraction, and development on those resources; and 3. Site-specific impacts of the Service’s permitting action on those resources, including direct and indirect effects.

For more information on the Typical Impacts of Well Drilling & Production Operations on National Wildlife Refuge System (NWRS) lands, see the Service’s “National Wildlife Refuge System Revision of Regulations Governing Non-Federal Oil and Gas Activities Environmental Impact Analysis” (Programmatic EIS). The Programmatic EIS (https://www.fws.gov/refuges/oil-and-gas/pdfs/FEIS- National-Wildlife-Refuge- System- Revision-of-Regulations-Governing-Non-Federal-Oil-and-Gas- Rights.pdf) provides a framework for taking a range of actions under the 29D Regulations, including the requirement that all new operators obtain an Operations Permit for new drilling and production operations to ensure those operations meet the various operating standards outlined in the regulations. The Programmatic EIS acknowledged that actions relating to new non-federal oil and gas development would require more site-specific analyses before they could be permitted. Therefore, this EA tiers from the programmatic EIS and provides additional site-specific analysis.

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NATURAL RESOURCES

AFFECTED ENVIRONMENT IMPACT EVALUATION

Geology & Soils: No Action Soils on Delta NWR are all formed in recent During site preparation, impacts on geology and soils occur as a result of Mississippi River alluvium and range from temporarily removing acreage from natural conditions and transferring fine sand to clay in texture. Imperfect to poor that area to an industrial use to accommodate the drilling rig and drainage is the rule, and flooding is frequent. associated equipment. The primary impact on soils from oil and gas wells in open water is a direct loss of submerged soil productivity in the footprint of the site and through installation of access canals, pipelines, gathering lines, or service lines.

Without engaging the Applicant in the permitting process, the well placement, access canals, and associated production equipment could be placed in ecologically sensitive habitat and occupy a greater footprint within the refuge.

In addition to construction-related impacts, there is a risk of impacts to soils from releases of hazardous or contaminating substances during drilling or production operations, including well workovers and servicing. These releases could occur from leaking equipment. In most cases, however, primary and secondary containment, of hazardous and contaminating substances, if implemented, should prevent the release of drilling muds, diesel fuel, oil and gas, and other substances beyond the drilling barge. Proposed Action To minimize impacts on the landscape the Applicant has proposed its drilling location within an open water pond, and access routes will utilize existing canals to the greatest extent possible. These proposed actions will only increase the Refuge’s current oil and gas footprint (on submerged soil productivity) by approximately 1.5 acres. This footprint will be for the life of the well. Flow line installation will not impact established, vegetated marsh, and only temporarily disturb waterways with unconsolidated soils.

Therefore, direct impacts on soils and geology are limited. Approximately 3,642 cubic yards of sediments will be disturbed and dispersed locally by prop-washing to site the drilling barge. If the well is successful, installation of the flowlines from the Delta Duck Location “B” Prospects to TPIC’s existing DDC Well U2 No. 16 and to the Delta Duck Central Facility will involve jetting in flowlines below the mud line. Given the dynamic nature of the submerged soil sediments, the additional one-time disturbance from prop-washing and jetting is expected to have negligible impacts on the sediments themselves or the habitat they provide.

The Applicant is proposing to use a zero discharge, self-contained drilling barge that will ensure that leaks and spills of hazardous or contaminating substances entering the environment will be avoided to the maximum extent practicable. The Applicant has submitted the

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NATURAL RESOURCES

AFFECTED ENVIRONMENT IMPACT EVALUATION drilling contractor’s SPCC plan (Appendix D) for drilling operations and TPIC’s (post-construction operator) Emergency Response Plan (ERP) as required under 40 CFR, part 112 (Appendix E). Adherence to these plans will help ensure that risks of spills are minimized and any spills or leaks that do occur will be reported to the Refuge and responded to in a timely manner. As a result, risks of these indirect impacts to emergent marsh/wetlands will be minimized or avoided to the maximum extent possible.

The Applicant is responsible for any damage to marshlands or wetlands as a result of such a spill or leak and must restore habitat to the Service’s standards (50 CFR 29.117(a), 120(g) and 29.151(a)).

Therefore, the Service has determined that the Applicant has proposed the most technologically feasible, least damaging methods in this instance, and has not added any additional stipulations to the Operations Permit. Air Quality: No Action Delta NWR is a designated Class II Clean Air The primary impacts on air quality from well drilling and production Area, as are most National Wildlife Refuges, include emissions from the barge and heavy equipment during drilling by the Clean Air Act. This means that limited of the well, as well as, emissions released during well maintenance and development (i.e. sources of pollution) can be production activities. permitted near the Refuge as long as the levels of particulate matter, sulfur dioxide, and The barge and heavy equipment used for the construction and nitrogen dioxide do not exceed the Class II maintenance of the well, flow lines, pipelines, and well drilling could increments. Air quality on the Refuge is introduce NOx, VOCs, CO, SO2, PM10, PM2.5, and odors from influenced by off-site sources including operating large engines, pumps, and auxiliary equipment. This can result petrochemical industrial facilities along the in short-term (drilling operations) to long-term (production operations) Mississippi River north and west of Delta impacts on air quality. NWR. Prevailing southeast winds transport relatively clean air to the Refuge for most of Drilling activities can involve continuous operation of combustion the year. engines over a 15- to 120-day period depending on the depth and complexity of the well drilled. This activity would introduce emissions of NOx, CO, and SO2. Large diesel engines, which are used to power the drill, rigs, pumps, and auxiliary equipment, emit NOx as primary pollutants of concern. Nitrogen oxides are formed in the high temperature, pressure, and excess-air environment of combustion diesel engines. Smaller amounts of CO and hydrocarbons would also be emitted. Some SO2 would be emitted due to the burning of gasoline and diesel (which contain minor amounts of sulfur). The amount of engine emissions depends on the drilling rig size (horsepower), percent sulfur in the fuel burned, gallons of diesel fuel burned per hour, the hours per day, number of days the diesel rigs operate, and the use of any emission control devices.

Exhaust from machinery used for drilling will contribute to an increase in particulate matter. As a result of increased particulate matter emissions, visibility may be slightly impacted during construction and

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NATURAL RESOURCES

AFFECTED ENVIRONMENT IMPACT EVALUATION drilling in any localized area where these activities are undertaken. There could be some added impact on regional visibility due to transport of fine particulate matter and haze produced by secondary aerosols (i.e., particulate matter formed from gaseous emissions of SO2, NOx, and VOCs, in particular).

The drilling barge used for the proposed operations is equipped with 3 Caterpillar D-398 diesel powered draw works and rotary engines, 2 Caterpillar 3516 diesel powered mud pump engines, 3 Caterpillar D- 3412 diesel powered generator sets, and 1 Caterpillar D-3306 diesel powered standby generator which power all of the drilling equipment and ancillary equipment on the barge. Drilling operations are expected to last 45 days with approximately 42 days of actual drilling and well completion operations (i.e., 24/7 operations).

Based on manufacturer’s data and 24 hour/day operation of above referenced diesel engines 100% load for 42 days, expected emissions for the drilling project are estimated to be:

Total NOX 96,715 lbs Total SO2 6,819 lbs Total CO 22,220 lbs Total PM 5,338 lbs Total VOC 8,216 lbs

Additionally, hazardous air pollutants that can be released during oil and gas operations are benzene, toluene, ethylbenzene, and xylene (known as the “BTEX” chemicals); hydrogen sulfide (H2S); arsenic (As); and mercury (Hg). These pollutants demonstrate a high toxicity and can lead to increased rates of cancer and respiratory disease in humans either acutely or chronically exposed to high concentrations in the environment. Existing concentrations of and potential exposures to these pollutants vary widely depending upon the physical characteristics of the site, the proximity of human populations, the level of oil and gas production, and the type of production equipment employed (Mall et al. 2007).

Odors from drilling and production operations could affect visitors and Refuge employees. The possibility and extent for odor would depend on wind speed and direction and the nature of the drilling equipment and material encountered during drilling operations (particularly the presence of H2S -bearing zones). Odor would be more noticeable during light breezes and less evident during periods of stronger winds.

For both existing and future operations, a leak or spill could cause hydrocarbons to volatize and enter the atmosphere. In the vicinity of the leak or spill, concentrations of gas and other constituents could present health hazards to animal and plant life, and even provide a source for an explosion or fire. Impacts from leaks or spills could be serious on a very local level; however, with mitigation, and prompt response, these

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AFFECTED ENVIRONMENT IMPACT EVALUATION impacts would be short-term. Although these impacts may be a localized event, they can contribute to regional air quality impacts.

Photochemical reactions between hydrocarbons and NOx produce ozone (Bradbury et al. 2013). Although the concentration of all these pollutants would increase as the fields are developed, the levels are expected to be low and are required to comply with Federal and State standards and conform to all local air quality State implementation plans (SIPs). The extent of impacts caused by increases in pollutants may range from areas near each well to longer ranges with low-level contributions to regional impacts, like ozone and haze formation.

NOx and SOx in the air can damage the leaves of plants, decreasing their ability to produce food – photosynthesis- and decrease their growth. In addition to directly affecting plants, atmospheric nitrogen deposition acts as fertilizer, favoring some plants, including invasive species, and leaving others at a competitive disadvantage. Sulfur oxides can acidify sensitive ecosystems resulting in a range of harmful deposition-related effects on fish and wildlife; plants; soils; and water quality. This creates an imbalance in natural ecosystems, and overtime may lead to shifts in the types of plant and animal species present, increases in insect and disease outbreaks, disruption of ecosystem processes (such as nutrient cycling), and changes in fire frequency.

Nitrogen deposition may disrupt soil nutrient cycling and alter plant communities. Invasive grasses thrive in areas with high nitrogen deposition, displacing native vegetation adapted to low nitrogen conditions. The fire risk subsequently increases due to extensive areas of weedy grasses.

The amount of air pollution generated over the productive life of oil or gas wells depends on the characteristics of the product and the production practices used. Emissions associated with production are usually considerably less than the emissions from well drilling. However, over the life of some production operations, emissions could exceed those of drilling operations. Oil and gas production operations release gaseous pollutants such as CO, hydrocarbons, NOx, and SO2. These production operation air pollutants are released from separation facilities, disposal of liquid waste and unwanted gas, burning of waste petroleum products, routine emission of objectionable odors, and venting of noxious vapors from storage tanks.

The Louisiana Department of Environmental Quality (LDEQ) regulates air quality in Louisiana. LDEQ does not require drilling rigs operating at one location for less than 1 year to obtain an air permit. The activity is approved by LDEQ as an insignificant activity on the basis of size, emission or production rate, or type of pollutant. (Reference: LAC 33:III. 501.B.5 Table 1.B.4) As such, the pollutants emitted to the ambient air directly or indirectly from the proposed construction activities would not significantly impact the ambient air quality of the region, and would not

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AFFECTED ENVIRONMENT IMPACT EVALUATION jeopardize compliance with State and Federal ambient air quality standards.

Operation of small boats and work boats is expected to be the primary mode of transportation to and from the well site. While vessels associated with the operation would generate emissions such as CO and NOx, they are anticipated to have no significant impact on regional air quality since these vessels are already part of the existing traffic in the area.

Proposed Action Since these exhaust emissions would not jeopardize compliance with State and Federal ambient air quality standards, and deterioration of air quality would be short- term (i.e. less than 90 days or duration of drilling operation) and not impact designated wilderness the Service has not identified additional mitigation measures as conditions of approval to this permit. Therefore, the impacts would be the same under the No Action and Proposed Action alternatives. Water Resources: No Action Hydrologically, Delta NWR is dominated by Without applying technologically feasible, least damaging methods there the Mississippi River. The constant flow of is a greater chance water resources could become contaminated with river water through the Refuge to Breton hazardous substances during drilling, production, servicing, or transport. Sound creates a salinity gradient from fresh There could be accidental spills of drilling mud, diesel fuel, and other water on the western side to brackish water chemicals during drilling operations, or leaks from containers or flow closer to the Gulf of Mexico. The marshes and lines. If drilling mud, fuels, or other chemicals are spilled in the water, ponds of Delta NWR range from fresh where the fluids could result in changes in water quality and possible violations influenced by the Mississippi River to brackish of water quality standards if these are not detected and remediated. closer to the shoreline with the Gulf of Mexico Contamination from the release of produced waters that contain salts and and Breton Sound. The water flow is open and other well drilling fluids and chemicals could also impact surface and dynamic and not managed by any control ground water. For example, such instances of leaks from salt-water structures on the Refuge. disposal wells and flowlines conveying oilfield brine, along with contamination from mechanical problems and improper operating In the operations area, water quality is good practices have been documented at Hagerman and Aransas National and generally considered ‘fresh’ during higher Wildlife Refuges in Texas and the Anderson Waterfowl Production Area water periods. As water levels in the river in northeastern Montana (M. Maddux and M. Borgreen pers. comm.). decrease the salinity increases more towards a brackish water environment. During the spring Because production could continue for 20 years or longer, the potential time a much heavier sediment load is observed for leaks and spills of hazardous substances from production operations in most waterways on Delta NWR. During the (including flowlines and pipelines) is greater than for any other phase of proposed operational period the sediment load oil and gas operations. Adverse impacts on water quality could occur is expected to be fairly high. The sediment load from accidental leaks and spills of drilling fluids or waste waters, is dependent on the river stage. By late hazardous waste spills (including diesel fuel), well blowouts, ruptures of summer/early fall the river stage generally flowlines and pipelines, and spills from vessels/tanker trucks. decreases which reduces sediment load and increases salinity. Chronic small leaks and spills could spread through various pathways, and over an extended period of time could become substantial and costly to remediate. The chances of undetected spills are greater if routine inspections are not performed.

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Faulty installation or corrosion of production casing might go undetected and could adversely impact groundwater, if hydrocarbons and/or produced waters migrate into an aquifer and contaminate groundwater. The severity of the impact would depend on the type of substance spilled (hydrocarbons, produced waters, chemicals, solvents, and fuels) and the size of area impacted, but impacts could be substantial. Oilfield brine spills can increase the bioavailability of some heavy metals as well as destroy the soil structure resulting in the significant reduction of infiltration rates (Vavrek et al. 2004). These brine impacted soils are usually devoid of vegetation and are susceptible to erosion. The loss of infiltration will result in increased runoff with impacts to nearby surface water in terms of salinity, and siltation. Impacts to the soils from oilfield brine spills remain for years (Vavrek et al. 2004). Brine spills can produce impacts, even in saltwater habitats. Seawater is considered 35, 000 ppm whereas Brine can potentially be as high as ~450,000 ppm.

Proposed Action To minimize surface impacts the Applicant has proposed to conduct the drilling operations in open water. The Service recognizes that unplanned incidents associated with oil and gas operations, such as well blowouts, present a risk of releasing hydrocarbons, drilling mud, and other contaminants that can adversely impact water resources. However, under this proposed action and implementation of technologically feasible, least damaging methods, accidents and incidents can be minimized. For example, as discussed above, the Applicant is proposing to use a zero discharge, self-contained drilling barge that will ensure that leaks and spills of hazardous or contaminating substances entering the environment will be avoided to the maximum extent practicable.

Prop-washing at the drill site to accommodate the drilling barge will temporarily redistribute approximately 3,642 cubic yards of sediment through the water to immediately adjacent areas. Additionally, connecting the flow lines from Delta Duck Location “B” Prospects to TPIC’s existing DDC Well U2 No. 16 and to the Delta Duck Central Facility will involve jetting in flow lines below the mud line, which will temporarily displace sediment into water column. Should the well be successful, installation of the 26,073 linear feet (8,443 feet of dual, four- inch-diameter and 17,630 feet of six-inch diameter flow lines) will involve the jetting of approximately 17,105 cubic yards of sediment. The associated increase in turbidity from this phase of construction is expected to be short-term and return to natural conditions within hours of project completion. Therefore, direct impacts to water quality from the proposed operations are expected to be very limited.

The Applicant has submitted the drilling contractor’s SPCC plan (Appendix D) for drilling operations and an ERP (Appendix E) as required under 40 CFR, part 112. Adherence to these plans will help ensure that risks of spills are minimized and any spills or leaks that do

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AFFECTED ENVIRONMENT IMPACT EVALUATION occur will be reported to the refuge and responded to within a few hours of discovery. As a result, risks of these indirect impacts to water resources will be minimized or avoided to the maximum extent possible. Additionally, the Applicant is responsible for any damage to water resources as a result of such a spill or leak and must restore habitat to the Service’s standards (50 CFR 29.117(a), 120(g) and 29.151(a)). In the event that the Refuge’s resources or values are damaged, the Service would seek remedy both in the form of reclamation and monetary compensation.

Therefore, the Service has determined that the Applicant has proposed the most technologically feasible, least damaging methods in this instance, and has not added any additional stipulations specific to water quality to the Applicant’s Permit. Marshlands/Wetlands: No Action Two basic marsh zones occur within the marsh Without implementing technologically feasible, least damaging methods habitat - fresh marsh nearest the main there is an increased risk of indirect impacts on wetlands from releases tributaries and the brackish marsh zone nearest of hazardous or contaminating substances during drilling or production the Gulf of Mexico. Approximately 60% of the operations, including releases from leaking equipment. As described in Refuge consists of the fresh marsh zone. The Geology and Soils, other hazardous or contaminated materials that may predominant plants in the fresh marsh zone are be accidentally released include drilling mud, produced waters delta duck potato, elephant ear, wild millet, containing high concentrations of salts, NORM, hydrocarbons, and other and three- square. The marsh is tidally flooded well drilling fluids. All of which have the potential to impact wetland in depths ranging from a few inches to 2-3 feet. vegetation in the Refuge units. These substances may contain relatively The fertile soil, vegetative composition, and large concentrations of dissolved salts, particularly sodium chloride, and shallow water environment result in a highly can have salt concentrations much greater than ocean water (Vavrek et productive habitat for fish and wildlife. al. 2004).

Salt stress is the major environmental factor that affects all vital plant processes such as growth, photosynthesis, protein synthesis, energy and lipid metabolism, and productivity (Parida and Das 2005). Instances of leaks from salt-water disposal wells and subsequent contamination occurring as the result of mechanical problems and improper operating practices have been documented at Hagerman and Aransas NWRs and the Anderson Waterfowl Production Area (WPA) (M. Maddux and M. Borgreen, pers. comm.). Oilfield brine spills can increase the bioavailability of some heavy metals as well as destroy the soil structure resulting in the significant reduction of infiltration rates (Vavrek et al. 2004). These brine impacted soils are usually devoid of vegetation and are susceptible to erosion.

The loss of infiltration will result in increased runoff with impacts to nearby wetlands in terms of salinity, and siltation. Impacts to the soils and wetlands from oilfield brine spills remain for years (Vavrek et al. 2004).

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Proposed Action Under the proposed action the drilling contractor will use a zero discharge, self- contained drilling barge that will ensure that leaks and spills of hazardous or contaminating substances entering the environment will be avoided to the maximum extent practicable. This barge will be on the Delta Duck Well Prospect No. 2 location for approximately 40 days. This drilling rig barge will be on Refuge for upwards of 42 days. The Applicant has submitted the drilling contractor’s SPCC plan for drilling operations and an ERP as required under 40 CFR, part 112. Adherence to these plans will help ensure that risks of spills are minimized and any spills or leaks that do occur will be reported to the refuge and responded to within a few hours of discovery. As a result, risks of these indirect impacts to water resources will be minimized or avoided to the maximum extent possible.

The Applicant is responsible for any damage to water resources as a result of such a spill or leak and must restore habitat to the Service’s standards (50 CFR 29.117(a), 120(g) and 29.151(a)).

Furthermore, the proposed flow lines will be jetted in, within existing open water canals and passes, so there will be no direct impacts from the installation of the flow lines on marshlands/wetlands. The only potential impacts to marshland/wetlands from the flow lines would be in the instance of a spill or leak.

Therefore, the Service has determined that the Applicant has proposed the most technologically feasible, least damaging methods in this instance, and has not added any additional stipulations specific to water quality to the Applicant’s Permit. Vegetation (including species of special No Action management concern): Without using technologically feasible, least damaging methods there is The predominant plants in the fresh marsh an increased risk of indirect impacts on vegetation from releases of zone are delta duck potato, elephant ear, wild hazardous or contaminating substances during drilling or production millet, and three-square. Low shrubs include operations, including well workovers and servicing. The presence of oils groundsel, wax myrtle, and marsh elder. and other well development chemicals in the water could kill vegetation Scattered throughout the understory where or adversely impact overall plant health. Additionally, contamination sunlight reaches the forest floor is a herbaceous from the release of produced waters containing salts and other well community of elephant ear and sedges. This drilling fluids could also impact vegetation in the refuge units. These habitat is valuable for cover for deer and small substances may contain relatively large concentrations of dissolved salts, mammals. The trees provide an important particularly sodium chloride, and can reach salinity levels as high as staging area for migratory birds because of the 450,000 ppm, which is more than 12x the salinity of seawater (~35,000 proximity to the Gulf of Mexico. Predominant ppm). Salt stress is the major environmental factor that affects all vital trees are black willow (along remnant spoil plant processes such as growth, photosynthesis, protein synthesis, energy banks) and red maple. and lipid metabolism, and productivity (Parida and Das 2005).

The proposed work area is located in an Accidental release of produced waters would likely damage or kill vegetation in the immediate area and possibly adjacent areas in the short-

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AFFECTED ENVIRONMENT IMPACT EVALUATION ‘intermediate marsh’ area which falls between term. Immediate adverse impacts on vegetation could occur through the predominant fresh marsh and brackish direct contact of aquatic vegetation with the released material. Long- marsh. These areas may contain both fresh and term, systemic impacts could also occur through uptake of the material salt tolerant plant species. The predominant from the soil by plant roots, thereby reducing the species’ ability to vegetation adjacent to the drill site is recover and re-establish (Adams et al. 2011). However, because the area Phragmites (Roseau Cane). of operations is within a hydrologically dynamic system that is frequently flushed with sediment laden water, dilution will likely lessen long-term impacts.

Use of barges and ships for construction and maintenance of the well and pipelines, could lead to an increase in the introduction of non-native plant species. Invasive species actively outcompete and replace native species and are a threat to the overall ecological health of the Refuge unit. Such introductions could negatively affect native plant communities, reduce diversity, reduce forest health and productivity, and degrade native wildlife habitat (Vila et al 2011; Tylianakis et al 2008).

Proposed Action Overall the proposed operations will be using existing open water and open water canals for both the well site and flow line installation, thus greatly reducing direct impacts to existing vegetation.

The Service has not identified any alternative technologically feasible, least damaging methods to require the Applicant to further mitigate or avoid impacts to the environment as related to control of non-native and invasive species. The area of the proposed operation is already highly impacted by the introduction of non-native and invasive species from many sources. Any mitigation measures placed on an Applicant to control invasive or non-native species would lead to no notable benefits in reducing the spread of these species in the area of operation or on the Refuge. Thus, the permitting action has had no impact on non-native or invasive species in the area of operations or on the Refuge.

As discussed above, the Applicant is proposing to use a zero discharge, self-contained drilling barge that will ensure that leaks and spills of hazardous or contaminating substances entering the environment will be avoided to the maximum extent practicable. The Applicant has submitted the drilling contractor’s SPCC plan for drilling operations and an ERP as required under 40 CFR, part 112. Adherence to these plans will help ensure that risks of spills are minimized and any spills or leaks that do occur will be reported to the refuge and responded to within a few hours of discovery. As a result, risks of indirect impacts to vegetation from spills and leaks will be minimized or avoided to the maximum extent possible.

Furthermore, the Applicant is responsible for any damages to vegetation as a result of such a spill or leak and must restore habitat to the Service’s standards (50 CFR 29.117(a), 120(g) and 29.151(a)).

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AFFECTED ENVIRONMENT IMPACT EVALUATION Therefore, the Service has determined that the Applicant has proposed the most technologically feasible, least damaging methods in this instance, and has not added any additional stipulations specific to water quality to the Applicant’s Permit. Wildlife (including species of special No Action management concern): If the Service did not engage the Applicant in the permitting process, Delta NWR is located in an extremely rich there is a chance of increased impacts to wildlife and habitat. The degree estuary system that is important to wading, sea, of impact would depend on the type and amount of habitat affected, the and shore birds, migratory waterfowl and rate at which the site would regenerate after construction, and the songbirds, crabs, shrimp, and both fresh and frequency of maintenance conducted during operation. Vegetation saltwater fish. Wintering waterfowl removal (both submerged and emergent) along with soil disturbance populations begin building on Delta NWR in associated with the construction and installation of the well and the fall and peak in mid-December and associated flow lines would affect wildlife both directly and indirectly. January. Recent surveys document 20,000 to Indirect effects would include short term loss of habitat through removal 30,000 snow geese and 80,000 to 150,000 of vegetation. This activity may also affect habitat structure, species ducks. The most common species observed are composition, and the extent of vegetation available to wildlife. Other gadwall, northern pintail, American wigeon, indirect impacts may include changes in distribution, stress, or activity blue-winged teal, green-winged teal, and snow caused by increased human disturbances associated with energy geese. The most common resident marsh and development (e.g., traffic, noise, human use) (Sawyer et al. 2002). water birds are great blue heron, little blue heron, white ibis, glossy /white- faced ibis, Fragmentation of existing wildlife habitats, which can occur from oil and great egrets, snowy egrets, tricolored herons, gas well development, can also decrease an area’s functional capacity to yellow-crowned night-herons, and black- support wildlife populations at non-impacted levels (Trombulak and crowned night- herons. The refuge serves as a Frissell 2000). Fragmentation refers to breaking up contiguous areas of staging area for many passerine birds during vegetation/habitat into smaller patches that become progressively migration, and large concentrations of smaller and isolated over time. shorebirds are sometimes observed feeding in the mudflats. Because of the lack of high Direct impacts to wildlife include increased mortality that could result ground, no large numbers of mammals exist on from boat activity, and increased activity associated with construction Delta, but a few white-tailed deer, rabbits, and and maintenance. Aquatic species that cannot escape an area during raccoons survive in this environment. The construction could be killed. These changes and uses of aquatic habitat invasive non-native nutria is probably the most may result in severe and persistent adverse effects on wildlife and abundant mammal on the Refuge. Invasive wildlife habitat in the Refuge units. feral swine are also very prevalent on the Refuge. Species that inhabit or frequent areas with sites that have had releases of oil or other chemicals could be harmed or killed through direct exposure In the immediate vicinity of the proposed with the released materials or indirectly through degraded water quality operation the most common wildlife are (e.g., low pH, reduced dissolved oxygen, or sediment toxicity). If there marsh, wading, and sea birds (e.g. rails, herons, are releases into waterways, wildlife and aquatic species occupying or egrets, and terns/gulls) along with resident fish using the water could be directly impacted. The severity of impacts and invertebrates (e.g. bass, gar, red drum, would depend on the type and amount of pollutant released, physical and shrimp, and blue crab). environmental factors of the site, the method and speed with which cleanup occurs, and the sensitivity of wildlife and aquatic species to these Federally Listed: Although an extremely rare impacts during various stages of their life cycle. The Service recognizes visitor, the West Indian Manatee can occur at that unplanned incidents associated with oil and gas operations such as Delta NWR, especially during the summer well blowouts, fires, and major spills within the boundaries of the Refuge months when water temperatures rise; and present a risk of release of contaminants that can adversely impact Gulf Sturgeon have been recorded in the Delta wildlife and aquatic species.

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AFFECTED ENVIRONMENT IMPACT EVALUATION NWR waters. Although species can be found at Delta NWR, both would be considered Contamination from the release of produced waters containing salts and infrequent visitors and neither have critical other well drilling fluids could impact wildlife resources in the Refuge habitat designated within the Refuge. Piping units. These substances may contain relatively large concentrations of plovers are also found along adjacent barrier dissolved salts, particularly sodium chloride, and can have salt beaches and may use some of the Refuge’s concentrations greater than ocean water. Releases of produced waters mudflats, but occurrence is not expected in the (brine) can create salt licks, which may affect the behavior of large near vicinity of the area of operation due to mammals and ungulates (Wiles and Weeks 1986). Oilfield brine spills habitat type. can increase the bioavailability of some heavy metals as well as destroy the soil structure resulting in the significant reduction of infiltration rates (Vavrek et al. 2004). Due to the extremely high salinity of produced water, even in saltwater habitats these brine impacted soils are usually devoid of vegetation and are susceptible to erosion. Releases of produced water with high salinity levels may cause mortality of aquatic organisms such as invertebrates, freshwater mussels, and fish sensitive to increased levels of salinity (Brittingham et al. 2014).

There may be aquatic species habitat degradation from placement of flow lines in areas where these species occur. These effects could decrease the long-term viability of populations as a result of long-term use. Some risk of direct mortality of aquatic species could occur if a pipeline ruptures or if toxic materials (such as diesel fuel or produced waste water) are spilled into the water.

Noise from drilling or well servicing operations would also impact wildlife. Potential adverse effects from well drilling and production could include changes in species distribution and use of the area, increased energy expenditure, decreased reproductive success (breeding and nesting success), deafness in species with specialized hearing, and increased stress levels from the noise and disturbance associated with these activities (Sawyer et al. 2002). Increased noise levels during the breeding season can create acoustic masking for species, such as birds, that communicate by sound (Bayne et al. 2008, Francis et al. 2009, Brittingham 2014). Drilling operations introduce noise with the highest measurements in the 90 dBA (A- weighted decibel) range for a period of one or two weeks, up to a few months; with noise coming mostly from multiple diesel engines. Therefore, noise impacts could be severe, but limited to a localized area and of relatively short duration. Longer term noise disturbance could come from compressors and pumps used during the production phase. This type of production equipment could operate continuously for the duration of the oil field’s viability.

Noise, and increased human presence during drilling and flow line installations may cause resident species of birds to move away from the immediate area to nearby areas of much the same habitat.

Proposed Action To reduce noise and other anthropogenic disturbance, drilling operations would occur when wintering waterfowl populations are not present.

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AFFECTED ENVIRONMENT IMPACT EVALUATION Additionally, the Refuge can close or restrict motorized public access in the area of operations, and limit or restrict airboat operations. With this authority, the Service can mitigate the effects of increased access due to oil and gas activities. Therefore, impacts to birds and other wildlife are expected to be adverse, but short-term, and minimal.

The temporary increase in turbidity from prop-washing and jetting bottom sediments will also temporarily disturb aquatic species. However, native fish, and other endemic aquatic species, are well adapted for rapid increases in turbidity that occur naturally throughout the area of operations and are expected to not be adversely impacted.

Production equipment (e.g. heater treater units) associated with oil and gas facilities have been documented to cause bat, migratory bird, and raptor mortality through asphyxiation or incineration. The Service can stipulate for operators to cover the exhaust stacks of heater treater units with a mesh or wire screen, thus avoiding or greatly reducing this type of mortality.

As discussed above, the Applicant is proposing to use a zero discharge, self- contained drilling barge that will ensure that leaks and spills of hazardous or contaminating substances entering the environment will be avoided to the maximum extent practicable. The Applicant has submitted the drilling contractor’s SPCC plan for drilling operations and an ERP as required under 40 CFR, part 112.

Adherence to these plans will help ensure that risks of spills are minimized and any spills or leaks that do occur will be reported to the Refuge and responded to in a timely manner. As a result, risks of impacts to wildlife from leaks and spills will be minimized or avoided to the maximum extent possible. Additionally, the Applicant is responsible for any damage to wildlife as a result of such a spill or leak and must restore habitat to the Service’s standards (50 CFR 29.117(a), 120(g) and 29.151(a)).

Direct impacts pertaining to the remaining infrastructure, following the completion of the drilling operation, are expected to be minimal as the Delta Duck Central Facility has been operational in the same location for decades and so species sensitive to these impacts to the environment are not present in the area of operation. The remaining wellhead structure (above water surface) will not cause substantial impacts. In fact, bird species have been observed using these structures as a perch while hunting or loafing. Climate Change: No Action Among the most serious consequences of Drilling and flow line installation are estimated to consume forecast climate change are sea level rise and approximately 80,000 gallons of diesel fuel which results in direct the likely increase in hurricane intensity and greenhouse gas (GHG) emissions of 2,404 metric tons of CO2 associated storm surge (U.S. Global Change equivalent.

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AFFECTED ENVIRONMENT IMPACT EVALUATION Research Program 2009). Global sea level is projected to rise during the 21st century at a Hydrocarbon ultimate recovery from the proposed well is unknown, but greater rate than during 1961 to 2003 (IPCC could range from zero for a dry hole to 250,000 barrels of oil and 2007). Subsidence, or land sinking, also 1,000,000 cubic feet of natural gas for a prolific Delta Duck Club Field contributes heavily to coastal erosion and land well over a productive life of up to 20 years. Consumption of the loss in Louisiana and the surrounding Gulf produced hydrocarbons could result in indirect GHG emissions ranging states. Geological modeling has suggested that from zero to 250,000 metric tons of CO2 equivalent. Fugitive methane the weight of Pleistocene sediments on the emissions and flash gas from oil would be insignificant contributors to coast of Louisiana can explain between 0.1 and GHG emissions compared to the actual consumption of products. 0.8 cm (0.04 and 0.3 inches) of sinking per year (NASA 2008). Proposed Action Predicted global sea level rise of 1-2 m, As noted, the action being considered is not whether or not to issue a coupled with local subsidence, which the permit to allow this operation to proceed, as it is the Applicant’s right NASA (2008) model predicts would be about to access and develop these resources, but rather to ensure that the 36 cm over the next 90 years in the vicinity of Applicant avoids or minimizes impacts from such activities to the Breton NWR and 50 cm near Delta NWR, maximum extent practicable. The Service acknowledges that could add up to more than 2 m of relative sea compliance with State and Federal law for GHG emissions should level rise by the end of the 21st Century. provide the technologically feasible, least damaging methods to avoid Absent of beach nutrition on Breton NWR and or minimize impacts to climate change. Therefore, the Service has not sediment capture on Delta NWR, both of these put any further stipulations on the Applicant to reduce the indirect or refuges will experience shoreline retreat and direct impact of the operation on climate change. The Service’s significant inundation. management and oversight of this proposed non-Federal oil and gas operation (proposed action) is therefore essentially the same as the no Predicted impacts of sea level rise include action alternative relative to GHG emissions. However, the proposed increased risks of coastal erosion, conversion action could result in very small, beneficial effects on GHG emissions, of wetlands to open water, increase in salinity because it gives the Service the authority to ensure that Applicant is of estuaries and freshwater aquifers and complying with Federal and State laws applicable to reduction of flooding for coastal communities (CCSP greenhouse gas emissions. 2009). Rising sea temperatures are expected to increase the frequency and strength of Finally, given the relatively short life-span of the well of up to 30 years hurricanes (Emanuel 2005). Stronger storms and its location in open water, climate change, including sea level rise, with higher wind speeds, more intense rainfall, is not expected to have any notable effect on operations. and more powerful surges are expected to cause more severe damage (Knutson and In regard to GHG emissions, the operator has to submit a GHG report Tuleya 2004). As sea level rises and salinities annually to the Environmental Protection Agency (EPA). This report increase, vegetation zones will migrate inland; includes the run time hours of drilling rigs, which are used in the present salt marsh will convert to open water, calculations for emissions. The drilling rigs runtime hours for each brackish marsh will become saline, freshwater engine will be documented and reported under the rule. marsh will become brackish, and freshwater swamps and shrub communities will convert to herbaceous systems as episodes of salt water intrusion become more frequent and occur further inland. Also predicted for south-central Louisiana by Karl et al. (2009) are changes in overall precipitation and in seasonal distribution of precipitation, and temperature averages and extremes. Current trends measured over the past century suggest that in southeast Louisiana, warming will continue,

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AFFECTED ENVIRONMENT IMPACT EVALUATION with more days over 90°F, fewer freezes, and longer frost-free periods, and precipitation will continue to decrease and to change distribution, with more fall precipitation and less precipitation during spring, summer, and winter. The likely extent of changes to the habitats of Delta and Breton NWRs is unclear. Wilderness: Typical Impacts of Well Drilling & Production Operations: There is no wilderness on Delta NWR. While Breton NWR is close in proximity to Delta NWR and is designated wilderness, there are no anticipated impacts from this proposed operation on Breton NWR.

VISITOR USE AND EXPERIENCE

AFFECTED ENVIRONMENT IMPACT EVALUATION Delta NWR is accessible by boat only. Hunting and fishing are the primary public uses on the Health and Human Safety - Refuge. It is open to waterfowl, archery deer, and rabbit hunting. Sport fishing is permitted No Action year-round during day-light hours, and only The primary source of impacts would be from drilling or production after 12:00 pm in the waterfowl hunting areas operations, especially if spills or leaks occurred and oil or other during the state waterfowl hunting season. chemicals were not quickly cleaned up and removed from the site.

Most abundant fresh water species caught are Drilling and production have the potential for well blowouts and releases of hydrocarbons or other hazardous substances, including drilling muds catfish, largemouth bass, and sunfish during and gases such as hydrogen sulfide (H2S). Visitors could also be drawn the spring and speckled seatrout and redfish in to well platforms out of curiosity, resulting in potential exposure to high the summer/fall. Because of the remoteness pressured equipment or stored chemicals. Hunters, in particular, need to and difficulty of access to the main portion of keep a safe distance from oil and gas operations; there is an inherent Delta NWR, most other public use activities hazard of shooting near drilling rigs and production facilities (i.e., rarely occur. storage tanks, wellheads, and pump jacks) where bullets could penetrate equipment or cause ignition of flammables. There is the possibility of storm damage to drilling and production operations, which could spread hazardous and contaminating substances. Perforating or rupturing a storage tank containing oil or treatment chemicals at a production facility would increase the threat of spills and subsequent harm to the public if they were to venture onto the site.

A potential impact on human health and safety is the possible exposure to hazardous substances. Materials stored at well sites include oils, chemicals, and lubricants. Also, oil and gas wells can release hydrogen sulfide gas. If well sites are not fenced and are open to the public, there is a chance of visitor exposure to these substances if visitors enter the unsecured site. Most wells would operate under an emergency response plan that would address hydrogen sulfide releases and other possible scenarios. For those wells that may emit hydrogen sulfide, a radius-of-

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AFFECTED ENVIRONMENT IMPACT EVALUATION exposure analysis would likely be performed prior to site selection. However, the Service recognizes that unplanned incidents associated with oil and gas operations such as well blowouts, fires, and major spills within the boundaries of the Refuge present a risk of release of contaminants that can adversely impact visitor use and experience by actual exposure to chemicals or from lack of access following an incident, depending on the location of the release.

Proposed Action Drilling would occur outside the hunting season and fishing opportunities are plentiful outside the immediate area of operations. However, the Service has stipulated that LLOX post signs at the drilling site warning the public to stay away from the immediate area of operations. Delta NWR regulations prohibit the use of rifled rounds or shotgun slugs and hunting within 250 yards from any oil and gas infrastructure.

If the well is successful, there would be the long-term presence of a well and platform during the production phase. The height of the well tree itself would be approximately 10 feet above water line and would only be visible in the immediate area. The well platform would be approximately 5 feet above the water line. A navigation light will be installed and is necessary for safety purposes and would minimize the risk of human collisions with the well.

Additionally, as discussed above, the Applicant is proposing to use a zero discharge, self-contained drilling barge that will ensure that leaks and spills of hazardous or contaminating substances entering the environment will be avoided to the maximum extent practicable. The Applicant has submitted the drilling contractor’s SPCC plan for drilling operations and an ERP as required under 40 CFR, part 112. Adherence to these plans will help ensure that risks of spills are minimized and any spills or leaks that do occur will be reported to the refuge and responded to within a few hours of discovery. As a result, risks of indirect impacts to human health and safety will be minimized or avoided to the maximum extent possible.

Therefore, the Service’s proposed action will have minor, beneficial impacts to human health and safety.

Access

No Action The primary effect of well drilling and production is a reduction in access to the area where any well sites and associated production facilities are located. Furthermore, if the Service does not engage the Applicant in the permitting process stipulations such as safety signs and access restrictions may be absent from construction site, potentially creating an increased risk to Refuge visitors.

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VISITOR USE AND EXPERIENCE

AFFECTED ENVIRONMENT IMPACT EVALUATION

Proposed Action All drilling and production operations would be closed to visitor access. Due to safety concerns, there may be additional restrictions to visitor access immediately adjacent to these sites. Indirect impacts, such as increased traffic, noise, odors, night lighting, and human activity, would not necessarily preclude recreational access, but would decrease the quality of the visitor experience in the vicinity of the operation, especially in more remote portions of the Refuge. Workovers and servicing of existing operations could also cause access delays or restrictions.

Therefore, the proposed operation may have some minor, adverse impacts on fishing opportunities on the Refuge. Drilling would occur outside the hunting season and fishing opportunities are plentiful outside the immediate area of operations. Visual Impacts/Scenic Views/Night Sky Resources

No Action Visual impacts on visitor experience from drilling and production operations could be more substantial than other types of impacts on visitors, especially if the well site was placed in relatively undisturbed or popular setting where visitors would be readily able to see the operation and all associated equipment and tanks, and visitors to that area were expecting or desiring a more natural experience. Drill rigs can reach heights of 180 feet, which would most likely be visible from several locations within the Refuge. The operations, especially drilling, would increase the presence of work crews and equipment. Since drilling is a 24-hour, 7-day a week operation, these impacts would be continuous, and could last a week or two, or up to a few months. Production operations, although having a less intrusive human presence compared to drilling, could be visible for 20 years or longer.

Coming across an oil drilling rig or production site could be an unpleasant experience for visitors seeking a natural, outdoor experience. The visual presence of oil and gas operations in a natural setting could adversely impact the areas by displacing the visitor or lessening the quality of the visitor experience. The impacts would be less for those visitors who are less concerned with the presence of such operations, and where operations are naturally screened from view. Oil and gas operations are a very common site for recreational users at Delta NWR and do not represent a notable conflict.

Lighting of drilling operations, which is typically provided using fluorescent high-pressure sodium or metal halide lamps, could interfere with night sky resources. Depending on where the operations are sited, the design and installation of lighting, and the amount of activity and type of equipment used during the night, impacts include disturbance of night-

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VISITOR USE AND EXPERIENCE

AFFECTED ENVIRONMENT IMPACT EVALUATION sky views, increase in overall sky glow and anthropogenic light rations, and disruption of wildlife behaviors like migration, predation and mating. The operations, especially drilling, would increase the presence of work crews and equipment. Since drilling is a 24-hour, 7- day a week operation, these impacts would be continuous, and could last for one or two weeks, or up to a few months.

Proposed Action Most of the visual impacts to the proposed area of operations would be temporary and would occur during the drilling of the well and installation of the flow lines when there would be an increase in ship and barge lights and traffic. The lights of the drilling rig could be visible for miles but would not be a singular or uncommon site. The drilling barge is expected to be on location for approximately 1.5 months. If the well is successful, there would be the long-term presence of a well and platform during the production phase. The height of the well platform would be approximately 5 feet above the water line and the well structure (tree) would be approximately 10 feet above water line and would only be visible in the immediate area. A navigation light is necessary for safety purposes, and also would not be visible outside the immediate area. Impacts to scenic views and night sky resources during the production phase would result during well maintenance that necessitate a workover barge. Impacts would be similar, but less in intensity and duration, than described for drilling operations, and the refuge may set time or seasonal restrictions on such operations. The proposed area of operation is located in an isolated location away from any local populations. Because it is located so far from local populations, there will be no impacts to scenic views or night sky resources for most of the public, as it will not be visible. The refuge is closed from one-half hour after sunset to one half hour before sunrise. Hunters and anglers will not be exposed to visual impacts at night. In addition, the only visitors to this area of operations are hunters and anglers. The proposed operations would have little additional cumulative impacts on enjoyment of visitors to the Refuge, because the natural visual setting is already highly impacted by existing oil and gas infrastructure. The Service has added one stipulation to the permit regarding scenic views/night sky resources: The drilling rig will have inward facing lighting, pointing down; minimizing negative effects of spill lighting on night sky or surrounding habitat.

Noise

No Action There would be increased noise from construction activities, barges and ships, drilling equipment, and the drilling or workover crew that could adversely affect human health, visitor use and experience, wildlife, and the overall acoustic environment. These noises would be different from the types of noises common in the visitor use areas, or general background noises elsewhere in the Refuge. Most of the adverse impacts associated with oil and gas operations within Refuge units would result from the drilling and production phase, because construction of the well necessitates the majority of the heavy construction equipment that have

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VISITOR USE AND EXPERIENCE

AFFECTED ENVIRONMENT IMPACT EVALUATION considerable sound levels, and production has a long duration. Potential sources of noise associated with drilling and production include preparation of the drill site, drilling operations, cement work, well servicing, and workover operations. Barge and ship traffic would also add to noise.

Predicted levels are representative of noise attenuation at a rate of 6 dBA per doubling of distance from the sound source (the noise level drop-off rate from a stationary point source purely due to the geometry of the source). Though additional attenuation could be realized due to vegetation cover, intervening topography and meteorological conditions, low frequency sounds commonly produced by mechanized equipment (like vehicles, pumps, and drill rigs) travel great distances.

Vegetation, certain meteorological conditions, and topography could reduce the distance at which noise levels from heavy construction equipment would attenuate to the natural ambient level.

If the drilled wells are advanced to the production stage, the use of heavy construction equipment to lay flow lines would result in elevated sound levels similar to those described above for the site access, preparation, and drilling.

The production phase would necessitate the use of some equipment that produces considerable amounts of noise, including gas compressors and jack pumps. These impacts would be continuous and long term, as pumping or gas compression would occur continuously over the life of the well. Additionally, over the course of time that the well is in production, well servicing and workover operations may be necessary. Depending on the maintenance necessary, well servicing may last only 1 or 2 days, requiring minor equipment and a workover rig (a scaled-down drilling rig). Major workover operations may last more than a month and could require some limited drilling operations.

Where proposed operations are located close to active recreation (e.g., motor boating), as it is with Delta NWR, the noise associated with the oil and gas operations would not be as noticeable.

Production operations would also cause impacts because of the noise associated with production equipment and the short-term use of loud machinery and workover rigs onsite. These impacts would result from high sound levels while being temporary in nature. However, most noise levels associated with production would have lower sound levels than those generated by a drilling operation yet would be continuous and could have other impacts to the soundscape, acoustic environment or the wildlife that rely on natural acoustic conditions.

The greatest impacts from noise due to proposed operations would be temporary, with the most noise occurring during the drilling of the well and installation of the flow lines due to increase in ship and barge traffic

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VISITOR USE AND EXPERIENCE

AFFECTED ENVIRONMENT IMPACT EVALUATION and the operating of heavy equipment for construction and installation during this time. However, there would also be continuing noise impacts during the production phase due to some ship and barge traffic during minor maintenance or operation of heavy equipment during any workover operations. The proposed area of operation is located in an isolated location away from any local populations, so any noise from proposed operations will not affect the majority of the public. The only visitors to this area of operations are hunters and anglers. The proposed operations would have little additional impact on enjoyment of these visitors to the refuge, because the natural setting of the area is already highly impacted by noise from existing oil and gas infrastructure. The adverse impacts to the enjoyment of visitors from the additional noise impacts would not be notable.

Proposed Action Noise from exploration, development, and extraction activities can be mitigated through a variety of ways including, but not limited to, use of quieter engines, quieter machinery, noise barriers, noise enclosures, and timing of operations to avoid the quietest times of day or certain seasons for which impacts would be greater (i.e., wintering waterfowl populations). However, neither the Service nor the Applicant has added stipulations to the permit regarding noise, therefore the impacts would be the same as analyzed under the No Action alternative.

CULTURAL RESOURCES

AFFECTED ENVIRONMENT IMPACT EVALUATION There are no known cultural resources on Delta There are no cultural resources in the proposed area of operations, as NWR. Geologically, the refuge is relatively confirmed through consultation in compliance with National Historical young and since formation little to no human Preservation Act Consultation, Section 106 (Appendix F). habitation or development has occurred.

REFUGE MANAGEMENT & OPERATIONS

AFFECTED ENVIRONMENT IMPACT EVALUATION

Administration No Action One Full Time Employee (FTE) is responsible Because the Service would not be administering, monitoring, and for monitoring all oil and gas activities for the enforcing permits, Service staff and resources for these types of activities Southeast Louisiana Refuges Complex. This would not be impacted under the No Action Alternative. However, when FTE will be responsible for monitoring the an operation is done without a permit there is a much higher likelihood drilling operation and all coordination with the that Refuge resources may be harmed. Unnecessary damages due to an operator during the operational phase through Applicant not using the most technologically feasible, least damaging completion. methods may require a significant amount of Service time and resources to correct such impacts. For example, accidents associated with oil and

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gas operations such as well blowouts, fires, and major spills within the boundaries of the Refuge could pose a severe impact on refuge management and operations. These types of accidents extended over the operational lifetime of oil and gas facilities can result in continued adverse impacts on refuge management and operations, depending on the number of operations and level of activity occurring within the Refuge at any one time. Depending on the degree of response and the amount of resources needed, these incidents could require additional staffing and the use of other refuge administrative and material resources.

Proposed Action Engaging the Applicant in the permitting process during the operational phases of drilling and production, would require Refuge staff and resources to evaluate the operation, and thus minimize adverse impacts and unnecessary damages. The effect on Refuge resources from problems, leaks and violations would be minimized to the greatest extent possible through base workload inspections and monitoring of a few staff. By working with the Applicant on permit stipulations (e.g. enforcement of timing stipulations for drilling and production operations in special management areas of the Refuge) the chance for unnecessary damages and need for additional Refuge staff and resources is greatly reduced.

SOCIOECONOMICS

AFFECTED ENVIRONMENT IMPACT EVALUATION Oil and gas operator costs and project financial viability No Action Even if the Service did not engage the Applicant in the permitting process, LLOX will still need to have the field bonded with the State of Louisiana to cover the plugging and abandonment, and reclamation cost. However, if not operating under technologically feasible, least damaging methods, the Applicant may encounter more frequent spills, potentially impacting critical habitat, resulting in fines and higher reclamation costs at the end of the operation. Proposed Action Costs specific to conducting private oil and gas operations under an SUP include the following:

1. Plan of operations preparation or permitting, 2. Compliance with Service permit requirements that exceed other Federal, State, and local requirements, 3. Compliance with Service reclamation standards that exceed other Federal, State, and local requirements, and 4. Maintenance of performance bonds or equivalent surety, if required.

These costs are normally a small percentage of a typical Applicant’s total expenses, but for some individual operations, these costs can become

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economically significant as production declines and profit margins constrict.

Although these administrative and operational costs are a part of the decision to develop wells and/or continue production for existing wells, they are not a major factor. The price of oil and gas, however, is an essential factor. The most important component is the operational and geological risk assessment that exploration and drilling will lead to successful and economical oil and gas production, and if so, at what level.

LLOX has indicated the costs described above could range up to $2,500,000 over the life of the project.

Regional and local economies No Action Sources of income are the seafood industry, the Oil and gas exploration and development support jobs and income in off-shore oil industry, shipping, and citrus nearby communities for drill rig operators, geophysical seismic groves. Millions of pounds of shrimp, oysters, companies, construction companies, landmen, and oil and gas support crab, and fish are produced annually by the companies that complete wells, among others. Oil and gas production commercial fishing industry. The parish is also supports industry jobs, including inspecting and maintaining equipment considered a “sportsman’s paradise” for sport and operations, complying with mitigation standards and other on-going fishing. Encompassing seventy miles of the production and operational needs. These residential and non-residential Mississippi River, Plaquemines Parish is the workers spend their wages in local and regional communities, supporting eighth largest port in the United States and is downstream jobs and income. Oil and gas production also provides noted for exporting coal, petro-chemicals, and economic benefits to oil and gas companies, benefiting economies where grain. these companies are headquartered and the nation overall. Many energy- related jobs provide higher wages and earnings than service sector jobs.

During production, the oil and gas value of production is often taxed through severance taxes and ad valorem taxes, although these taxes vary by State. Additionally, local governments often benefit from property and sales and use taxes on oil and gas equipment. These tax receipts typically benefit State and county agencies.

Proposed Action The proposed operations do not have the potential to notably affect local and regional economies. The proposed operations represent a negligible percentage of oil and gas development and production occurring in adjacent parishes and regions. The typical benefits described above would thus be very minimal.

Oil and gas activities could interfere with the public’s use of a Refuge reducing the Refuge’s contributions to local and regional economies. However, as discussed above, the impacts to visitor use would be minimal, so the Service’s permitting action would have no impact on the regional or local economy.

ENVIRONMENTAL JUSTICE Executive Order 12898, Federal Actions to The Service does not anticipate that the Service’s regulation of non- Address Environmental Justice in Minority Federal oil and gas on refuges would result in disproportionately high or Populations and Low-Income Populations, adverse impacts on low-income populations or communities. The requires all Federal agencies to incorporate Service analyzed the anticipated costs of the regulation on operators environmental justice into their missions by compared to data from the U.S. Economic Census and found regulatory

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identifying and addressing disproportionately costs to represent less than 1 percent of average annual receipts for high or adverse human health or environmental typical businesses conducting oil and gas operations in the NWRs. Based effects of their programs and policies on on this information, the Service does not believe that this permitting minorities and low-income populations and action has been a major factor in the Applicant’s decision of where to communities. develop wells on the refuge, and this will not result in disproportionately high or adverse impacts on low-income populations or communities. Guidelines for implementing this executive order under NEPA are provided by the Council on Environmental Quality (CEQ) (CEQ 1997) and require the Service to evaluate whether a proposed action has the potential to have disproportionately high and adverse impacts on minority and/or low income populations typically involves the following: (1) identifying any potential high and adverse environmental or human health impacts; (2) identifying any minority or low income communities within the potential high and adverse impact areas; and (3) examining the spatial distribution of any minority or low income communities to determine if they would be disproportionately affected by these impacts.

INDIAN TRUST RESOURCES There are no Indian Trust Resources on this This action will not impact any Indian Trust Resources. Refuge.

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Cumulative impacts are defined as “the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or person undertakes such other actions”.

Past, Present, and Reasonably Foreseeable Activity in Area Descriptions of Cumulative Actions of Analysis Invasive and exotic species. The area of the proposed operation is already highly impacted by the introduction of non-native and invasive species from a multitude of sources, including the entire Mississippi River system and its tributaries.

LLOX's proposed action is not expected to have any discernable beneficial or adverse impacts related to invasive species, and thus the permitting action has had no effect on the cumulative impacts of non-native or invasive species in the area of operations or on the Refuge.

The Service has not added stipulations to the permit related to the control of non-native and invasive species. Wildlife-dependent recreation The area of operation is in an area where recreational fishing opportunities exist, as well as migratory waterfowl hunting during the open hunting season. The Service has stipulated that drilling will occur outside of the migratory waterfowl hunting season and outside of the open waterfowl hunting area, so it will not contribute to the cumulative impacts on hunting opportunities. The Service has not identified any notable conflicts from long-term production of the well with hunting or fishing. Production operations will not cause any long-term impairment to the habitat, vegetation, or water quality, so the proposed operation will only negligibly add to the cumulative impacts of wildlife-dependent recreation in the area. In addition, future plugging and reclamation of existing wells is likely to wholly offset any adverse cumulative impacts from the proposed action. Past and Future oil and gas The proposed operation is in an area that has a long history of oil and gas development on refuge and exploration and development. This has resulted in a highly impacted marsh in adjacent lands the areas where drilling and production have been concentrated.

Currently, Plaquemines Parish has over 7,000 active producing oil and gas wells. On Delta NWR alone there are 29 active oil and gas wells, 70 inactive wells, and 77 historic wells that have been plugged and abandoned. The matrix of canals and drilling slips are a legacy of past technologies that highly favored straight holes directly above their bottom hole targets. Existing oil and gas fields could readily be further developed using directional drilling. Additionally, the number of actively producing wells is declining in Plaquemines Parish as new drilling has been out paced by well plugging and abandonment.

Therefore, the Service’s permitting of this facility in the proposed location will not lead to additional habitat fragmentation, due to the use of pre-existing canals and open water; and thus, not contribute to cumulative impacts.

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Past, Present, and Reasonably Foreseeable Activity in Area Descriptions of Cumulative Actions of Analysis Impacts to natural resources and visitor use due to construction activities, such as soils, habitat, noise, air quality, and erosion would contribute only slightly to cumulative impacts since they are typically localized and temporary. No impairment to these resources and uses would result from the proposed operations or the Service’s permitting of that operation.

Furthermore, the Service has put stipulations on operations that will result in beneficial impacts to human health and safety, such as requiring additional signage to inform refuge visitors of the potential hazards of the operation. These signs will help educate visitors about the hazards of present and future development, leading to some minor beneficial cumulative impacts to human health and safety from the Service’s permitting action.

It is reasonably foreseeable that the Applicant or other Applicants with non- Federal oil and gas rights may propose other operations to develop minerals on the Refuge and in the local area. The impacts of such activities would be similar to those analyzed above. The largest impacts to the environment from oil and gas development have already happened due to the large-scale development of oil and gas infrastructure that has already occurred. The extent of historical exploration in the area (seismic and drilling) reduces the probability that large undiscovered resources will be found and create extensive new development. Rather, economics will likely be the driver of continued low rate of new well drilling. Continued development of oil and gas resources combined with plugging and reclamation activities yield an overall trend of environmental improvements related to oil and gas activities in the area. Commercial Navigation The Port of South Louisiana is the largest tonnage port in the western hemisphere. The lower Mississippi River adjacent to the Refuge maintains a steady flow of marine traffic 24 hours a day. The additional marine traffic related to this drilling operation will have negligible impacts to the commercial navigation of the lower Mississippi River.

Measures to mitigate and/or minimize adverse effects have been incorporated into the selected action. These measures include:

• Adverse effects to surface/marshland are minimized through: o Use of existing open water canals for access o Placement of drill rig and well in an open water pond o Jetting flowlines in open water canals

Due to the nature of oil and gas activities, there is always a risk to public health or safety, as well as wildlife and habitat; from leaks, spills or emergencies. However, the risk of these incidents occurring is very low, especially when the Applicant has proper procedures in place for avoiding, mitigating, and responding to such incidents, as does this Applicant with their contract driller’s SPCC plan, as well as the future operator’s Emergency Response Plan.

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The Applicant has demonstrated that they have a right to develop these non-Federal oil and gas rights on the refuge, therefore, the Service’s action is to issue the Applicant an Operations Permit that ensures that the Applicant is using technologically feasible, least damaging methods to do so, as required by 50 CFR part 29 subpart D. This action, which will result in several stipulations placed on the Applicant in the proposed Operations Permit as well as continued monitoring and enforcement by the Service for the life of the operation, as analyzed in this Environmental Assessment, will result in minimal individual and cumulative beneficial environmental impacts.

1. Joseph Ranson – USFWS, Field Supervisor– Ecological Services – Lafayette ES Office 2. Kristin P. Sanders – State of Louisiana – State Historic Preservation Officer

On February 1, 2019, consultation letters were submitted to the following tribes: The Chitimacha Tribe of Louisiana; Coushatta Tribe of Louisiana; Choctaw Nation; Jena Band of Choctaws; Mississippi Band of Choctaws; the Tunica-Biloxi Tribe; and the Seminole Nation. Responses were received from the Jena Band of Choctaws and the Choctaw Nation have been received. The remaining Tribes have not responded as per the date of this submittal. Copies of the responses from Jena Band of Choctaws and Choctaw Nation are included as Appendix H.

Adams, M.B., P.J. Edwards, W.M. Ford, J.B. Johnson, T.M. Schuler, M. Thomas-Van Gundy, F. Wood. 2011. Effects of development of a natural gas well and associated pipeline on the natural and scientific resources of the Fernow Experimental Forest. Gen. Tech. Rep. NRS-76. Newtown Square, PA: U.S. Department of Agriculture, Forest Service, Northern Research Station. 24 p. Available at: http://www.fs.fed.us/nrs/pubs/gtr/gtr_nrs76.pdf. Accessed January 14, 2015

Bayne, E.M, L. Habib, and S. Boutin. 2008. Impacts of chronic anthropogenic noise from energy-sector activity on abundance of songbirds in the boreal forest. Conservation Biology 22(5): 1186-1193. Bradbury, J., M. Obeiter, L. Draucker, W. Wang, and A. Stevens. 2013. “Clearing the Air: Reducing Upstream Greenhouse Gas Emissions from U.S. Natural Gas Systems.” Working Paper. Washington, DC: World Resources Institute. Available at: http://www.wri.org/publication/clearing-the-air.

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Bradbury, James, Michael Obeiter, Laura Draaucker, Wen Wang, and Amanda Stevens. 2013. Clearing the Air: Reducing Upstream Greenhouse Gas Emissions from US Natural Gas Systems. Washington: World Resources Institute.

Brittingham, M.C., K.O. Maloney, A.M. Farag, D.D. Harper, and Z.H. Bowen. 2014. Ecological risks of shale oil and gas development to wildlife, aquatic resources and their habitats. Environmental Science and Technology. 48(19): 11034-47.

CCSP, 2009: Coastal Sensitivity to Sea-Level Rise: A Focus on the Mid-Atlantic Region. A report by the U.S. Climate Change Science Program and the Subcommittee on Global Change Research. [James G. Titus (Coordinating Lead Author), K. Eric Anderson, Donald R. Cahoon, Dean B. Gesch, Stephen K. Gill, Benjamin T. Gutierrez, E. Robert Thieler, and S. Jeffress Williams (Lead Authors)], U.S. Environmental Protection Agency, Washington D.C., USA

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IPCC, 2007: Climate Change 2007: Synthesis Report. Contribution of Working Groups I, II and III to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change [Core Writing Team, Pachauri, R.K and Reisinger, A. (eds.)]. IPCC, Geneva, Switzerland, 104 ppKarl, T. et al. 2009. “Global Climate Change Impacts in the United State” Author: U.S. Global Change Research Program. Publisher: Cambridge University Press”

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This analysis also incorporated information from sources referenced in the Delta and Breton National Wildlife Refuge’s Comprehensive Conservation Plan and Environmental Assessment (https://www.fws.gov/southeast/planning/PDFdocuments/Delta%20Breton%20Final/DeltaBretonFinalCC Pdoc.pdf); the Habitat Management Plan for Delta and Brenton National Wildlife Refuges (https://catalog.data.gov/dataset/habitat- management-plan-for-delta-and-breton-national-wildlife- refuges); and the Programmatic EIS for National Wildlife Refuge System Revision of Regulations Governing Non-Federal Oil and Gas Activities (https://www.fws.gov/refuges/oil-and-gas/pdfs/FEIS- National-Wildlife- Refuge-System-Revision-of-Regulations-Governing-Non-Federal-Oil-and-Gas- Rights.pdf).

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• Lee Womack – Matrix New World Engineering, Land Surveying, and Landscape Architecture, PC. – Senior Project Manager • Barret Fortier – Senior Wildlife Biologist – Southeast Louisiana Refuges – USFWS • Jimmy Laurent – Delta NWR Refuge Manage/Regional Energy Coordinator Southeast Region – USFWS

This Environmental Assessment will be available for public review and comment for 30 calendar days on the Southeast Louisiana Refuges Complex website: (https://www.fws.gov/southeastlouisiana/)

A paper copy will be available at the Southeast Louisiana Refuges Complex Headquarters, located at: 61389 Hwy 434, Lacombe, LA 70445

This final determination will be made after the public comment period.

☐ The Service’s action on this permit application will not result in a significant impact on the quality of the human environment. See the attached “Finding of No Significant Impact”. ☐ The Service’s action on this permit application may significantly affect the quality of the human environment and the Service will prepare an Environmental Impact Statement.

Preparer Signature: Date:

Name/Title/Organization:

Certifying Officer Signature: Date:

Name/Title/Organization:

18-1083 Delta Duck Well Prospect No. 2 EA 38

Existing TPIC Facility Latitude 29.245297° £ Longitude -89.199786° Delta Duck Well Prospect No. 1 Latitude 29.241376° Longitude -89.155912°

Delta Duck Well Prospect No. 2 Latitude 29.233333° Longitude -89.162500°

Existing TPIC Well Latitude 29.223133° Longitude -89.179818°

Legend Delta Duck Well Prospect No. 1 Site Location Map Delta Duck Well Prospect No. 2 Environmental Assessment Delta National Wildlife Refuge, Plaquemines Parish, Louisiana Existing TPIC Facility Existing TPIC Well LLOX, LLC Alternate Flowline Routes Delta Duck Well Prospect No. 2 2,500 1,250 0 2,500

Feet Drawn By CET Approved By LAW Source: Base map comprised of U.S.G.S. 7.5-minute topographic map(s), "Main Pass, LA" Date 2/1/2019 1 dated 1971; and "Pass A Loutre West, LA" dated 1993. Drawing No. 18-1083-A004 Figure No.

£

Legend Delta Duck Well Prospect No. 2 Alternate Route A Existing TPIC Facility Environmental Assessment Delta National Wildlife Refuge, Plaquemines Parish, Louisiana Existing TPIC Well Required Flowline Route (8,443 linear feet) LLOX, LLC Alternate Route A (17,041 linear feet) Delta Duck Well Prospect No. 2 2,000 1,000 0 2,000

Feet Drawn By CET Approved By LAW Date 3/20/2019 2a Source: Base map comprised of ESRI World Imagery. Figure No. Drawing No. 18-1083-A005

£

Legend Delta Duck Well Prospect No. 2 Alternate Route B Existing TPIC Facility Environmental Assessment Delta National Wildlife Refuge, Plaquemines Parish, Louisiana Existing TPIC Well Required Flowline Route (8,443 linear feet) LLOX, LLC Alternate Route B (21,680 linear feet) Delta Duck Well Prospect No. 2 2,000 1,000 0 2,000

Feet Drawn By CET Approved By LAW Date 3/20/2019 2b Source: Base map comprised of ESRI World Imagery. Figure No. Drawing No. 18-1083-A005

£

Legend Delta Duck Well Prospect No. 2 Alternate Route C Existing TPIC Facility Environmental Assessment Delta National Wildlife Refuge, Plaquemines Parish, Louisiana Existing TPIC Well Required Flowline Route (8,443 linear feet) LLOX, LLC Alternate Route C (22,019 linear feet) Delta Duck Well Prospect No. 2 2,000 1,000 0 2,000

Feet Drawn By CET Approved By LAW Date 3/20/2019 2c Source: Base map comprised of ESRI World Imagery. Figure No. Drawing No. 18-1083-A005

£

Legend Delta Duck Well Prospect No. 2 Alternate Route D Existing TPIC Facility Environmental Assessment Delta National Wildlife Refuge, Plaquemines Parish, Louisiana Existing TPIC Well Required Flowline Route (8,443 linear feet) LLOX, LLC Alternate Route D (30,880 linear feet) Delta Duck Well Prospect No. 2 2,000 1,000 0 2,000

Feet Drawn By CET Approved By LAW Date 3/20/2019 2d Source: Base map comprised of ESRI World Imagery. Figure No. Drawing No. 18-1083-A005

£

Legend Delta Duck Well Prospect No. 2 Alternate Route E Existing TPIC Facility Environmental Assessment Delta National Wildlife Refuge, Plaquemines Parish, Louisiana Existing TPIC Well Required Flowline Route (8,443 linear feet) LLOX, LLC Alternate Route E (29,490 linear feet) Delta Duck Well Prospect No. 2 2,000 1,000 0 2,000

Feet Drawn By CET Approved By LAW Date 3/20/2019 2e Source: Base map comprised of ESRI World Imagery. Figure No. Drawing No. 18-1083-A005

£

Legend Delta Duck Well Prospect No. 2 Alternate Route F Existing TPIC Facility Environmental Assessment Delta National Wildlife Refuge, Plaquemines Parish, Louisiana Existing TPIC Well Required Flowline Route (8,443 linear feet) LLOX, LLC Alternate Route F (24,560 linear feet) Delta Duck Well Prospect No. 2 2,000 1,000 0 2,000

Feet Drawn By CET Approved By LAW Date 3/20/2019 2f Source: Base map comprised of ESRI World Imagery. Figure No. Drawing No. 18-1083-A005

£

Legend Delta Duck Well Prospect No. 2 Alternate Route G Existing TPIC Facility Environmental Assessment Delta National Wildlife Refuge, Plaquemines Parish, Louisiana Existing TPIC Well Required Flowline Route (8,443 linear feet) LLOX, LLC Alternate Route G (15,085 linear feet) Delta Duck Well Prospect No. 2 2,000 1,000 0 2,000

Feet Drawn By CET Approved By LAW Date 3/20/2019 2g Source: Base map comprised of ESRI World Imagery. Figure No. Drawing No. 18-1083-A005

£

Legend Delta National Wildlife Refuge (48,799 acres) Delta National Wildlife Refuge

LLOX Lease Environmental Assessment Delta National Wildlife Refuge, Plaquemines Parish, Louisiana LLOX, LLC Delta Duck Well Prospect No. 2 2 1 0 2 Miles Drawn By CET Approved By LAW Source: Base map comprised of ESRI World Imagery. National Wildlife Refuge (NWR) data Date 2/1/2019 3 obtained from U.S. Fish and Wildlife Service, Division of Realty. Drawing No. 18-1083-A006 Figure No.

£

Legend Delta and Breton Delta National Wildlife Refuge National Wildlife Refuges Breton National Wildlife Refuge Environmental Assessment Delta National Wildlife Refuge, Plaquemines Parish, Louisiana LLOX, LLC Delta Duck Well Prospect No. 2 20 10 0 20 Miles Drawn By CET Approved By LAW Source: Base map comprised of ESRI StreetMap USA data. National Wildlife Refuge (NWR) Date 2/1/2019 4 data obtained from U.S. Fish and Wildlife Service, Division of Realty. Drawing No. 18-1083-A007 Figure No.

FARMOUT AGREEMENT

DELTA DUCK CLUB AREA PLAQUEMINES PARISH, LOUISIANA

This Farmout Agreement ("Agreement"), dated April 23, 2018 ("Effective Date"), is between Mobil Oil Exploration & Producing Southeast, Inc. , Inc., a Delaware corporation, whose address is P.O. Box 4610, Houston, Texas 77210-4610, ("ExxonMobil") and LLOLA, L.L.C., a Louisiana limited liability company, whose address is 1001 Ochsner Blvd, Suite A, Covington, LA 70433 ("Farmee"), hereinafter referred to individually as "Party" or collectively as "Parties".

This Agreement will govern and determine the rights and obligations of the Parties and the conduct of Farmee's operations, both as to the Initial Well and as to any subsequent well(s) which may be drilled under the terms of this Agreement or which may be drilled on the Farmout Area after a Conveyance has been earned by Farmee.

In consideration of the mutual promises in this Agreement, the benefits each Party derives, and other good and valuable consideration, ExxonMobil and Farmee agree as follows:

ARTICLE 1

DEFINITIONS

1.01. Actual Drilling Operations. Penetrating the surface of the earth with a drill bit by a drilling rig that is capable of drilling to the Objective Depth.

1.02. Additional Well. A well drilled subsequent to the drilling of the Initial Well or Substitute Well as provided in Articles 3.04 and 3.05.

1.03. Agreed Interest Rate. Interest compounded on a monthly basis at the rate per annum equal to the one (1) month term at the prime rate in effect at Citibank N.A. of New York, New York plus one (1) percentage point(s), applicable on the first business day prior to the due date of payment and thereafter on the first business day of each succeeding calendar month. If the aforesaid rate is contrary to any applicable usury law, the rate of interest to be charged will be the maximum rate permitted by such applicable law.

1.04. Assoc iated Party or Parties. Successors, assigns, directors, officers, employees, agents, contractors, subcontractors, and affiliates. When ExxonMobil assigns interests to Farmee or Farmee's successors pursuant to the terms of this Agreement, Farmee or Farmee's successors will not be considered an Associated Party of ExxonMobil. When Farmee assigns interests to ExxonMobil or ExxonMobil's successors pursuant to the terms of this Agreement, ExxonMobil or ExxonMobil's successors will not be considered an Associated Party of Farmee .

1.05. Claims. Collectively, claims, damages, expenses (including court costs and attorney's fees), civil fines, penalties, demands, causes of action, and lawsuits asserted or filed by any person, including an artificial or natural person; a local, state, or federal government entity; a person holding rights under any Related Agreement; an Associated Party of Farmee or ExxonMobil; or a third party.

1.06. Completion or Complete. One or more operations conducted in a wellbore with the intent to make a well a Producer of oil and gas in one or more zones, including, but not limited EM Contract No. 6008015

to, the setting of production casing, perforating, well stimulation and production testing conducted in such operation .

1.07. Conveyance. An assignment of leasehold and/or a lease of ExxonMobil mineral fee, as applicable, earned by Farmee under the terms and provisions of this Agreement. Any such Conveyance will consist of one hundred percent (100%) of ExxonMobil's present right, title and interest in and to the Lease(s), as defined herein, subject to the limitations and reservations provided herein.

1.08. Earned Interests. Oil and Gas rights extending from the surface to the stratigraphic equivalent of the base of the deepest producing zone in which the Earning Well is Completed and within that portion of the Farmout Area either 1) within a compulsory pooled unit, established under the applicable compulsory pooling laws, or a voluntary pooled unit; or 2) in the absence of the establishment of a compulsory or voluntary pooled unit, Farmee will earn the Farmout Area. In no event will Farmee be entitled to earn any interest below base of the 10,500' sand, being the stratigraphic equivalent of the sand seen between 9,553' and 9,726' measured depth in the electric log for the Texaco Delta Duck Club Unit #019 (Serial #32515). For further identification, the top of the 10,500' sand is also seen at 10,180 feet measured depth in the electric log for the Texaco Delta Duck Club Unit #016 (Serial# 32146). Notwithstanding the foregoing, the Earned Interest shall not include Oil and Gas rights in Section 5, T21S-R20E, Plaquemines Parish, Louisiana, from the surface down to 9,767 feet below the surface unless and until ExxonMobil is furnished a release of the expired lease covering said lands from the lessee of record.

1.09. Environmental Laws. Applicable federal, state, and local laws, including statutes, regulations, orders, ordinances, common law, rules, decrees, orders, or regulations relating to the environment, hazardous substances, materials, or waste, toxic substances, pollutants, or words of similar import, or environmental conditions at, on, under, or originating or migrating from any prope rty, or soil, water and groundwater conditions, including, but not limited to, the Comprehensive Environmental Response, Compensation and Liability Act of 1980, as amended, 42 U.S.C. § 9601, et seq., the Resource Conservation and Recovery Act, 42 U.S.C. § 6901, et seq., the Toxic Substances Control Act, as amended, 15 U.S.C. § 2601, et seq., the Clean Air Act, as amended, 42 U.S.C. § 7401, et seq., the Federal Water Pollution Control Act, as amended, 42 U.S.C. § 1251, et seq., the Federal Hazardous Materials Transportation Act, 49 U.S.C. § 1801, et seq., any amendments to the foregoing, and any similar federal, state or local laws, statutes, ordinances, rules, decrees, orders, or regulations, including those enacted in the future.

1.10. Farmout Area. The lands described on the attached Exhibit "1" and depicted on the attached Exhibit "1-A" plat. The Farmout Area shall be revised to include the depths in Section 5, T21S-R20E, Plaquemines Parish, Louisiana, from the surface down to 9,767 feet below the surface if ExxonMobil is furnished a release of the expired lease from the lessee of record and covering said lands.

1.11. Gas Well. A well classified as a gas well by the applicable Regulatory Agency.

1.12. Initial Well. The first well to be drilled on the Farmout Area as provided in Article 3.02.

1.13. Lease(s). The oil and gas lease(s) and/or mineral servitude interest(s) that are committed to this Agreement, as described in the attached Exhibit "1", subject to the limitations and reservations provided herein.

2 EM Contract No. 6008015

1.13. Lease(s). The oil and gas lease(s) and/or mineral servitude interest(s) that are committed to this Agreement, as described in the attached Exhibit "1", subject to the limitations and reservations provided herein.

1.14. Liabilities. All damages (including, but not limited to, consequential and punitive damages, including those for personal injury, death, or damage to personal or real property, both surface and subsurface, and costs for remediation, restoration, or cleanup of contamination ), whether the ·damages occurred or occur on or off the Farmout Area by migration, disposal , or otherwise; losses; fines; penalties; expenses; costs to remove or modify facilities on or under the Farmout Area; plugging liabilities for all Wells; attorney's fees; court and other costs incurred in defending Claims or lawsuits; liens; and judgments; whether any of the foregoing are foreseeable or unforeseeable. Liabilities also includes, but is not limited to, damages arising under or pursuant to Environmental Laws.

1.15. Objective Depth. The depth and/or formation to which the Initial Well will be drilled as provided in Article 3.02.

1.16. Oil and Gas (whether capitalized or not). The oil, gas, casinghead gas, gas condensate, and all other liquid or gaseous hydrocarbons and other marketable substances produced therewith, including, however, only the sulfur that is produced incidental to or in conjunction with the production of or processing for sale of any oil, gas, casinghead gas, gas condensate, and all other liquid or gaseous hydrocarbons. All sulfur that is produced or mined by other methods is excluded.

1.17. Oil and Gas Rights. Any necessary rights and duties under the applicable Lease(s) to explore for, develop, produce and transport Oil and Gas.

1.18. Oil Well. A well classified as an oil well by the applicable Regulatory Agency.

1.19. Producer. A well that is capable of producing oil and/or gas in paying quantities.

1.20. Regulatory Agency. Any municipal, local, state and/or federal agency having jurisdiction and/or regulatory oversight of oil and gas operations, including any such agency with oversight of environmental matters relating to oil and gas operations.

1.21. Related Agreement(s). All lease(s), assignments, subleases, farmouts, operating agreements, easements, rights-of-way, gas sales contracts, and other contracts and agreements pertaining to the Farmout Area, to the extent they are binding on ExxonMobil and/or Farmee.

1.22. Reserved Royalty Interests. Royalties equal to:

(a) On oil produced and saved from the lands and Lease(s) committed hereto, the difference between twenty-five percent of eight-eighths (25% of 8/8ths) and the total nonparticipating royalties and payments out of production as of the Effective Date, the oil to be delivered free of costs at the wells or to the credit of ExxonMobil into the pipeline(s) to which the wells may be connected or otherwise as ExxonMobil may from time to time direct. If ExxonMobil elects not to take the above-described royalty on oil in kind, then ExxonMobil will be paid the market value at the well for ExxonMobil's portion of the oil.

3 EM Contract No. 6008015

eighths (25% of 8/Bths) and the total nonparticipating royalties and payments out of production as of the Effective Date, provided that on gas so sold by Farmee in an arm's-length transaction to a non-affiliated purchaser the market value will not exceed the amount received by Farmee for the gas computed at the mouth of the well, and on gas so sold at the well the royalty will be the difference between twenty-five percent of eight-eighths (25% of 8/Bths) and the total nonparticipating royalties and payments out of production as of the Effective Date of the amount realized by Farmee from the sale. ExxonMobil may elect, in lieu of the cash payment of the gas royalties herein described, to take its proportionate share of the production in kind at any time or from time to time.

1.23. Substitute Well. A well drilled pursuant to Article 3.04 and intended to replace the Initial Well.

1.24. Well(s) (whether capitalized or not). All wellbores, both abandoned and unabandoned, including Oil Wells, Gas Wells, injection wells, disposal wells, and water wells.

ARTICLE 2

BONUS CONSIDERATION

It is expressly understood and agreed that Farmee will tender, as additional consideration for this Agreement, to the attention of Ms. Shannon Parker, Banking Technician, Mobil Oil Exploration & Producing Southeast, Inc., P.O. Box 4610, Houston, Texas 77210-4610, a cash payment of One Hundred Twenty Five Thousand Two Hundred Eight and 00/100 Dollars ($125,208.00) along with the executed Agreement on or before fifteen (15) days from the Effective Date. Farmee's failure to timely and properly tender such payment will, at ExxonMobil's option, render this Agreement null and void. It is understood and agreed that this additional consideration will not be refundable for any reason, including, but not limited to the failure of title as to any interest conveyed under or covered by this Agreement.

ARTICLE 3

DRILLING OF WELLS BY FARMEE

3.01. Rights of Farmee. Farmee will have the right to drill wells on the Farmout Area during the term of this Agreement in accordance with the provisions of this Agreement.

3.02. Initial Well. Farmee will commence Actual Drilling Operations for the drilling of the Initial Well, on or before April 23, 2019 time being of the essence, at a regular location on the Farmout Area. The location of the well will not require an exception to the spacing and/or density rules of the applicable Regulatory Agency.

Farmee will drill the Initial Well with due diligence and in a good and workmanlike manner to a depth of 9,600 feet below the surface or a depth sufficient to adequately test the 10,000' sand, whichever depth is shallower, being the Objective Depth.

Farmee will drill the Initial Well in a good faith effort to discover oil and/or gas and to test adequately all oil and/or gas shows encountered.

4 EM Contract No. 6008015

Farmee will Complete the Initial Well either as a Producer or plug and abandon the well, in compliance with Article 13, as a dry hole within one hundred and eighty (180) days from commencement of Actual Drilling Operations on the well.

Farmee will drill and Complete the Initial Well free of any cost or Liabilities to ExxonMobil, whether such well is Completed as a Producer or plugged and abandoned as a dry hole.

3.03. Grant, Exercise, and Termination of Option to Extend Actual Drilling Operations.

(a) ExxonMobil hereby grants to Farmee the option to extend the date by which Farmee must commence Actual Drilling Operations for the drilling of the Initial Well for an additional twelve (12) months.

(b) To exercise the option granted in this Article 3.03, Farmee must tender to the attention of Ms. Shannon Parker, Banking Technician, Mobil Oil Exploration & Producing Southeast, Inc., P.O. Box 4610, Houston, Texas 77210-4610, a cash payment of One Hundred Twenty Five Thousand Two Hundred Eight and 00/100 Dollars ($125,208.00), along with written notification of Farmee's election to exercise the option, on or before April 23, 2019. It is understood and agreed that such option consideration will not be refundable for any reason, including, but not limited to the failure of title as to any interest conveyed under or covered by this Agreement. If Farmee does not commence Actual Drilling Operations on or before April 23, 2019 and Farmee does not properly exercise the option according to the terms of this Article 3.03(b), then the option and the Farmout Agreement will expire and Farmee will not have any right to drill or earn acreage under this Agreement.

3.04. Substitute Well. In the event Farmee fails to reach the Objective Depth in the Initial Well, due to mechanical failure, the encountering of impenetrable substances, or similar conditions rendering further drilling impracticable to the extent that a prudent operator would not continue the drilling thereof, Farmee may abandon the well and commence operations at a regular location on the Farmout Area for the drilling of a well (sometimes referred to as "Substitute Well") to the same Objective Depth provided for in the Initial Well. The location of the Substitute Well must not require an exception to the spacing and/or density rules of the applicable Regulatory Agency. If Farmee chooses to drill the Substitute Well, Farmee must commence Actual Drilling Operations on the well within ninety (90) days after the abandonment of the Initial Well, and proceed to drill in a diligent effort to attain the Objective Depth. The Substitute Well will be drilled pursuant to the terms, conditions, and rights provided in this Agreement for the Initial Well.

3.05. AdditionalWell if Initial Well is Dry. If the Initial Well or the Substitute Well is drilled and then plugged and abandoned as a dry hole, and Farmee has complied with all the terms and conditions of this Agreement applicable to its operations to date, then Farmee may drill an Additional Well if not more than one hundred and eighty (180) days elapse between the date the Initial Well or the Substitute Well is plugged and abandoned as a dry hole, or the date of primary rig release, whichever is earlier, and the date Farmee commences Actual Drilling Operations on the Additional Well. The Additional Well will tje drilled pursuant to all the terms, conditions, and rights provided in this Agreement for the Initial Well.

3.06. Additional Well(s) if Initial Well is Producer. If the Initial Well, the Substitute Well, or the Additional Well is a Producer, and Farmee has complied with all terms and provisions of this Agreement, then Farmee may earn the balance of the Farmout Area, if any, on a well-by-well basis, by drilling one or more Additional Wells, provided that Farmee must commence Actual

5 EM Contract No. 6008015

3.06. Additional Well(s) if Initial Well is Producer. If the Initial Well, the Substitute Well, or the Additional Well is a Producer, and Farmee has complied with all terms and provisions of this Agreement, then Farmee may earn the balance of the Farmout Area, if any, on a well-by-well basis, by drilling one or more Additional Wells, provided that Farmee must commence Actual Drilling Operations for each Additional Well within one hundred and eighty (180) days after the earlier of: 1) the completion date of the last well drilled, as indicated on the completion report filed with the applicable Regulatory Agency; or 2) the date of primary rig release of the last well drilled. Each well drilled hereunder will be subject to all the terms, conditions, and rights provided for the drilling of the Initial Well.

ARTICLE 4

WELL INFORMATION

4.01. Exxon Mobil's Access to Well and Well Information. During the drilling of any well hereunder, ExxonMobil's representatives are to have access at all times, at ExxonMobil's sole risk and expense, to the well and to all cores, cuttings, logs, and other information of whatever nature obtained in the drilling of the well.

4.02 Furnishing of Well Information. As to each well drilled under this Agreement, or lands pooled therewith, and at any time while this Agreement is in effect, Farmee will provide to ExxonMobil copies of all forms and reports filed with any Regulatory Agency, and, at its sole cost and expense, promptly furnish all samples , cores, cuttings, depths, logs and other data specified in the Data Requirements, attached as Exhibit "2", as well as any other information obtained from said well or wells whether specifically set forth herein.

4.03 Furnishing of Other Well Information. At ExxonMobil's request, Farmee will promptly furnish all data specified in Article 4.02 for any well drilled within one (1) mile of the Farmout Area in which Farmee has an interest.

ARTICLE 5

EARNED INTERESTS

5.01. Earned Interests. If the Initial Well, the Substitute Well, or an Additional Well provided for in this Agreement is Completed as a Producer (an "Earning Well"), ExxonMobil has been furnished a completion report filed with the applicable Regulatory Agency, and Farmee has complied with the other conditions of this Agreement, Farmee will earn a Conveyance of the Earned Interests for such Earning Well.

Each Conveyance of Earned Interests will be effective as of the completion date, as indicated on the completion report filed with the applicable Regulatory Agency. The Earned Interests will be subject to the interests and rights reserved or retained by ExxonMobil pursuant to this Agreement. The Earned Interests will not include any conveyance of ExxonMobil surface fee interests. If the Earned Interests include ExxonMobil mineral fee, the ExxonMobil mineral fee will not be conveyed to Farmee, rather, the Oil and Gas Rights in the ExxonMobil mineral fee as to the Earned Interests will be leased to Farmee.

6 EM Contract No. 6008015

5.02. Plat(s) and Description(s). Farmee will provide ExxonMobil with a plat, field notes, and a legal description for the Earned Interests within sixty (60) days of the Completion of the Earning Well. The legal description must be acceptable to ExxonMobil and be such that it can be used as the description in any Conveyance of the Earned Interests. Farmee will be responsible for the payment of surveying and other costs incurred in preparing said plat(s), field notes, and legal description( s).

5.03. Form of Conveyance. The form of Conveyance earned by Farmee will be the form(s) attached as Exhibit "4". The Conveyance will be without warranty of title, express or implied.

5.04. Recording of Document(s). Farmee will promptly record the Conveyance document(s) in the appropriate governmental records and provide a copy of the recorded document(s) to ExxonMobil at no cost.

5.05. Reservations by ExxonMobil. Notwithstanding anything herein to the contrary , all production, royalties, overriding royalties, and revenues owned by ExxonMobil as of the Effective Date are excluded from this Agreement and are reserved unto ExxonMobil. See also Article 21 - Exclusions.

ARTICLE 6

POOLING AND UNITIZATION

The size, shape, and depth interval(s) of any voluntary pooled unit will be subject to ExxonMobil's written consent and approval, provided that such consent will not be unreasonably withheld.

ExxonMobil must review, approve, and execute the agreement or designation instrument for any unit before it is filed for record. The agreement or designation instrument will be recorded in a timely manner but not later than ninety (90) days after completion of drilling operations on the initial unit well. A certified copy of the recorded instrument will be furnished to ExxonMobil no later than fifteen (15) days after its recordation.

Farmee will be solely responsible for obtaining any agreements that may be required from mineral and/or royalty owners for the formation of any voluntary pooled unit under the provisions of this Agreement , and to the extent Farmee fails to obtain such consent, it will bear any additional burdens on production, and any other obligations or Liabilities, resulting from such failure.

ARTICLE 7

INTERESTS RESERVED BY EXXONMOBIL

7.01. Reserved Royalty Interests. In any Conveyance of the Earned Interests, ExxonMobil will reserve the Reserved Royalty Interests. The Reserved Royalty Interests will be decreased proportionately if the interest to be conveyed to Farmee covers less than the entire and undivided fee interest in the lands described in the Conveyance.

Notwithstanding any provision in this Agreement to the contrary, if the price of any substance upon which the Reserved Royalty Interests are payable is regulated by any

7 EM Contract No. 6008015

governmental agency, the market value or market price of the substance for the purpose of computing the Reserved Royalty Interests hereunder will not be in excess of the price which Farmee may receive and retain.

No development, operation, or production costs will be deducted when determining the amount of the Reserved Royalty Interests. The Reserved Royalty Interests will be free of all taxes except applicable gross production and severance taxes. ExxonMobil reserves the right to take in kind any of the Reserved Royalty Interests in oil, gas, casinghead gas and liquid constituents; and should ExxonMobil so elect, ExxonMobil will bear all costs incurred in taking in kind.

Payment by Farmee of the Reserved Royalty Interests under any Conveyance hereunder must be made from the date of first production and at all times thereafter on the basis of one hundred percent (100%) of the well's production (reduced to that percentage of the production that is attributable to the interests covered by any Conveyance hereunder) and the payments must be made regardless of whether Farmee is or is not selling all or any part of Farmee's share of the total production and regardless of the identity of the purchaser(s) of the production. Such th payments will be made on or before the twenty-fifth (25 ) day of the second calendar month after the month in which such royalties accrued. Division Orders covering the Reserved Royalty Interests will be sent to ExxonMobil's Property/Title Analysis Group (see attached Exhibit "5").

The failure of Farmee to commence the payment of the Reserved Royalty Interests within six (6) months from and after the date of first production will result in interest accruing at the Agreed Interest Rate on the total unpaid balance for production attributable to the Earned Interests.

ExxonMobil, upon written notice to Farmee, will have the right to audit or inspect Farmee's books, accounts, or records pertaining to the production, sale, or other disposition of oil and/or gas allocated to the Earned Interests and the payment of royalties and overriding royalties on production from the Earned Interests. The provisions of this paragraph will be applicable during the term of this Agreement and for a period of three (3) years thereafter. If errors or deficiencies are identified by an audit or otherwise, Farmee will take prompt corrective action and advise ExxonMobil thereof.

7.02. Escalation After Payout. For any Earning Well, ExxonMobil's Reserved Royalty Interests shall automatically increase, on a well-by-well basis, to the difference between twenty-seven and one-half percent of eight-eighths (27.5% of 8/Sths) and the total royalties, overriding royalties, and payments out of production as of the Effective Date at such time as the net proceeds, defined below, from the sale of all Oil and Gas produced from the well provided herein, or credited to the well, either by reason of transferred allowable, unit allocation, or any other means, attributable to the Earned Interests hereunder, equals one hundred percent (100%) of the cost and expense, both tangible and intangible, of drilling, equipping (an oil well through the oil storage tanks and a Gas Well through the Christmas tree), testing and completing the well for production, and of operating the well to the point of one hundred percent (100%) of the costs attributable to the Earned Interests. The "net proceeds" are defined as the total proceeds received from or credited or allocated to production, less severance, production and other taxes payable on production therefrom (except for production-based ad valorem taxes), and less all royalties, shut-in royalties, overriding royalties and payments out of production in effect as of the Effective Date. For purposes of determining net proceeds only, the Reserved Royalty Interests will be included in determining the overriding royalties and royalties in effect as of the Effective Date.

8 EM Contract No. 6008015

The period during which the net proceeds are to be applied against costs will be known as the "payout period". Charges and expenditures to be made by the Farmee will be made in accordance with and accounted for as set forth in the Accounting Procedure attached as Exhibit "6". During this payout period, nothing in this Agreement will be construed as constituting joint operations, the Accounting Procedure being intended only to govern the accounting for costs and expenditures incurred during the payout period. Upon completion of the well as a Producer, and as soon thereafter as the information may be obtained, Farmee, as operator, will furnish the individual or office identified as ExxonMobil's Financial/Payout Data Recipient (see Exhibit "5") the cumulative costs of drilling, completing, and equipping the well as a Producer on a form showing the same information as the form attached as Exhibit "7". Each calendar month thereafter and until payout, Farmee will likewise furnish a report, in duplicate, showing the cumulative current month's costs to operate the well. This report will also include the total volume of all substances produced, the value received for Farmee's share of the production, and the values credited to the Earned Interests for said well. This monthly report will be on a form showing the same information as the form attached as Exhibit "8". ExxonMobil will have the right to audit Farmee's records pertaining to all costs of any well during drilling, the payout period, and subsequent to payout, in accordance with the audit provisions in the Accounting Procedure attached as Exhibit "6"; provided that ExxonMobil will have the further right to audit records of all proceeds, operating expenses, and expenditures, including, but not limited to, the cost of drilling, completing, and equipping any well(s), for two (2) years after the end of the calendar year in which Farmee informed ExxonMobil, in writing, that payout occurred. Farmee will notify ExxonMobil, in writing, of payout within thirty (30) days of the payout.

Should the Reserved Royalty Interests escalate as herein provided, the increased Reserved Royalty Interests will become effective as of 7:00 a.m., local time where the well is situated, on the day following the day during which the payout will have occurred. Further, if the Reserved Royalty Interests are to increase, Farmee will, after payout of each well, make, execute, and deliver to ExxonMobil a recordable instrument evidencing that payout has occurred and that the Reserved Royalty Interests have increased.

ARTICLE 8

RIGHT TO PURCHASE OIL

For purposes of this Article only, "Oil" will mean crude oil, distillate, condensate, drip gasoline, and other liquid hydrocarbons.

ExxonMobil will have, for the life of the lease(s) in any conveyance concerning Earned Interests, the preferential right to purchase from time to time all or any portion of the Oil, which may be produced and saved from or allocated to the Earned Interests conveyed by ExxonMobil hereunder, except for that Oil which is used for operations upon and for the sole benefit of the Earned Interests. The price to be paid will be a mutually agreeable negotiated price, with transportation charges deducted, where applicable.

Notwithstanding anything herein to the contrary, if Farmee receives a bona fide bid from an independent third party, firm for ten (10) business days, to purchase the above Oil, which Farmee is willing to accept, then Farmee will furnish ExxonMobil with a copy of said bid and will give ExxonMobil the option (but not the obligation) to match such bid and purchase such Oil on terms identical to that contained in the bid. The option to ExxonMobil will also be firm for ten (10) business days. A copy of the third party bid, which will be signed and on the third party's company

9 EM Contract No. 6008015

letterhead, will be furnished to ExxonMobil for this purpose. A scanned electronic copy of the bid on the company letterhead is acceptable. The bid will include the contract term, volume, price, delivery location, relevant transportation costs, quality bank provisions, payment terms, and other terms including the ten (10) day firm bid period. Notice of ExxonMobil's election to match said bid and purchase the Oil will be provided in writing to Farmee within ten (10) working days after ExxonMobil's receipt of such bid.

Should ExxonMobil, on any one or more occasions, elect not to purchase or not respond within ten (10) working days after notification by Farmee, then ExxonMobil's right to purchase Oil will be considered temporarily waived until such time as the terms change in Farmee's contract to sell to the third party or Farmee's contract with the third party expires or until such time as ExxonMobil is willing to match the independent third party's bid, consistent with the cancellation notice period of said bid.

ARTICLE 9

RIGHT TO PURCHASE GAS

9.01. Right to Purchase Gas. ExxonMobil will have the continuing right for a period of twenty-one (21) years from the Effective Date, to purchase all gas which may be produced from or allocated to the interest in the lands conveyed by ExxonMobil hereunder; except that no such right will be applicable to gas used for operating purposes or gas subject to existing gas contracts (including only those renewals or extensions which are required to be granted by Farmee under the terms and conditions of the existing gas contracts) for so long as the gas may be subject to the existing gas contracts.

(a) Notification.

(i) This Article will apply at any time that Farmee proposes to enter into a contract to sell gas production to any purchaser. For purposes of this Article, the following definitions will apply:

"Spot Sale Contract" will mean a contract to purchase all or a part of any gas production if the contract provides for either of the following:

(1) the gas buyer and seller must enter into monthly renegotiation of the sales price of the production under the contract; provided, however, that the ultimate duration of the contract, including all extensions, is expressly limited to a period of no more than one (1) year; or

(2) the primary term of the contract is one (1) month or less, but may be extended, by the terms of the contract, for a period or periods; provided, however, that the ultimate duration of the contract, including all extensions, is expressly limited to a period of no more than one (1) year.

"Long-Term Contract" will mean any contract to purchase all or a part of any gas production if the contract is not a Spot Sale Contract.

(ii) If Farmee elects to produce the gas and receives a bona fide offer which Farmee finds acceptable to enter into a Long-Term Contract, then Farmee will promptly furnish written notice thereof and a copy of the offer together with flow rates,

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reserve estimates, and all data available on the well(s) that will be subject to the offer to ExxonMobil's Gas Purchase Notice Recipient (see Exhibit "5"). ExxonMobil will have thirty (30) days after receipt of the notice and all of the above data, to elect to enter into a contract to purchase the gas on the same terms and conditions as were obtained in the offer.

(iii) If Farmee elects to produce the gas and receives a bona fide offer which Farmee finds acceptable to enter into a Spot Sale Contract, then Farmee will promptly provide ExxonMobil with written notice of Farmee's intent to enter into the Spot Sale Contract. The notice need not be received by ExxonMobil prior to execution of the Spot Sale Contract. The notice will be addressed to the same address set forth in the preceding paragraph and will specify the volume to be sold, the term of the proposed Spot Sale Contract, and whether Farmee intends to continue making sales under Spot Sale Contracts indefinitely or seeks to enter into a Long-Term Contract(s). If Farmee intends to continue making sales under Spot Sale Contracts, the notice will constitute continuing notice to ExxonMobil that Farmee will make sales under Spot Sale Contracts until Farmee elects to discontinue making sales under the Spot Sale Contracts or elects to sell the gas production under a Long-Term Contract(s). When a change in plans occurs, Farmee will promptly notify ExxonMobil at the address set forth in the preceding paragraph of the change in planned marketing arrangements, and, in the case of contemplation of marketing under a Long-Term Contract(s), the terms of the preceding paragraph will apply.

(b) Election Not to Purchase. If ExxonMobil fails to notify Farmee, within thirty (30) days of the day ExxonMobil receives Farmee's notice, that ExxonMobil elects to exercise its right to purchase the gas production, then ExxonMobil will have no right to purchase the gas during the original contract primary term.

If ExxonMobil fails to exercise its right and, for any reason, Farmee does not thereafter accept the offer and enter into a legally binding contract, or if the contract expires or is terminated or canceled within the twenty-one (21) year period aforesaid, then, ExxonMobil's right to purchase gas will continue in full to any new offer for the production within the aforementioned period, all as described above.

9.02. Sale of Gas Subject to ExxonMobil's Rights. Notwithstanding anything in this Agreement to the contrary, any sale of gas by Farmee from the Farmout Area, without regard to whether ExxonMobil retains, reserves, or exercises any preferential right to purchase gas from the Farmout Area, will be subject to ExxonMobil's reserved right and election to take the Reserved Royalty Interests in kind (and any right ExxonMobil may have to convert the Reserved Royalty Interests to a working interest) and any such royalties taken in kind will be owned and controlled by ExxonMobil free and clear of any commitment to or obligation under the sale. If ExxonMobil elects to take the Reserved Royalty Interests in kind, the taking in kind will be subject to the Gas Balancing Agreement attached as Exhibit "3".

9.03. Preferential Right to Purchase or Transport and Fractionate (NGL}.

(a) Definitions. "Raw Make" will mean a mixture of liquid hydrocarbons consisting predominantly of ethane (C2), propane (C3), isobutane (IC4), normal butane (NC4), and pentanes

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plus (C5+) which are condensed from, absorbed from, or separated from natural gas and which meets the specifications of the Raw Make Pipelines as defined in the Raw Make Agreement.

"Option Raw Make" will mean Raw Make processed from natural gas produced from or allocated to ExxonMobil's interest in the Farmout Area , wells or production subject to this Agreement that may be capable of reasonable commercial delivery to any of the Raw Make Pipelines .

"Model Raw Make Agreement" will mean ExxonMobil's Model Raw Make Agreement.

(b) Nature of Right. Subject to the terms herein, ExxonMobil will have for itself and for any of its affiliates or subsidiaries the continuing preferential right and option for a period of ten (10) years from the Effective Date to purchase or transport and fractionate ("T&F") the Option Raw Make.

(c) Third Party Offers and Notice Requirements. If Farmee elects to produce Option Raw Make and receives a bona fide third party offer acceptable to Farmee for the purchase or T&F of all or part of such Option Raw Make, Farmee will promptly furnish ExxonMobil written notice (unless ExxonMobil has waived the applicable preferential purchase right in writing) of such offer, with full information about the offer, including, but not limited to, the name of the prospective purchaser (which must be ready, willing and able to purchase or T&F the Option Raw Make according to the terms of its offer), the full consideration offered for the purchase, and all other terms of the offer. Such notice will be sent to ExxonMobil's NGL Supply & Logistics Manager (see Exhibit "5"). ExxonMobil (or any one of its affiliates or subsidiaries) will have thirty (30) days after receipt of such notice to provide written notice to Farmee of its election to enter into an agreement with Farmee to purchase or T&F such Option Raw Make on the same terms and conditions as were contained in the third party offer; provided however, that unless substantial differences exist between the third party offer and the terms and provisions contained in the Model Raw Make Agreement, Farmee agrees to enter into a sale or T&F agreement with ExxonMobil (or any affiliate or subsidiary of ExxonMobil) under the terms and provisions contained in the Model Raw Make Agreement. If ExxonMobil (or any affiliate or subsidiary of ExxonMobil) should fail to notify Farmee within such thirty day period of its election to exercise its preferential rights hereunder, then Farmee will be free to enter into an agreement with such prospective purchaser to sell or T&F Option Raw Make on the terms contained in its notice to ExxonMobil.

EXXONMOBIL DOES NOT WARRANT ANY MARKET FOR OPTION RAW MAKE.

ARTICLE 10

SURVIVAL OF INTERESTS RESERVED BY EXXONMOBIL

If Farmee or Farmee's Associated Parties secure a renewal, extension, or replacement of a Lease subject to this Agreement, then the rights reserved or retained by ExxonMobil herein, including the Reserved Royalty Interests, will apply to such acquisition. Farmee agrees to

12 EM Contract No. 6008015

promptly grant an assignment of such reserved or retained rights to ExxonMobil in recordable form.

For the purposes of this Article a renewal, extension, or replacement lease, will be deemed to include any lease covering the same mineral interest as the Lease(s), whether it covers the entire interest covered by said Lease(s) or only a portion of its area or an interest therein, which is acquired before the expiration of its predecessor Lease, or acquired or contracted for or becomes effective within one (1) year after the expiration of the existing Lease.

ARTICLE 11

FARMEE'S OPERATIONS

11.01 Compliance. Farmee will conduct all its operations under this Agreement in a good and workmanlike manner and in full compliance with: 1) all applicable federal, state, and local laws, rules and regulat ions, including Environmental Laws; and 2) all express and implied covenants of the Lease(s) and other agreements covering interests in the Farmout Area . Farmee will keep the Farmout Area free and clear of all liens and encumbrances of every kind created by or arising from its operations.

11.02 Offset Well(s). If a lessor or royalty owner demands that a well be drilled on the Farmout Area or acreage within the Farmout Area be released, or, if in ExxonMobil's opinion (provided said opinion is consistent with that of a reasonably prudent operator), the Farmout Area is being drained by an offsetting well ("Draining Well"), ExxonMobil may notify Farmee of the action that ExxonMobil recommends to protect the Farmout Area from drainage or to satisfy the demand. Farmee will have thirty (30) days after the receipt of written notice to either comply with ExxonMobil's recommendation(s) or provide ExxonMobil with alternative recommendations. Provided, however, if ExxonMobil's recommendation is to drill a well on the Farmout Area, Farmee will have ninety (90) days after the receipt of the notice to commence Actual Drilling Operations on a well in order to protect the Farmout Area from drainage or to satisfy the demand. Unless ExxonMobil and Farmee agree upon a manner to protect the Farmout Area from drainage or to address the demand, Farmee will release from this Agreement the following acreage: 1) if a demand is made as provided above, the portion of the Farmout Area that is reasonably necessary for ExxonMobil to address the demand; or 2) if in ExxonMobil's opinion (provided said opinion is consistent with that of a reasonably prudent operator), the Farmout Area is being drained by a Draining Well, the portion of the Farmout Area that is reasonably necessary to offset the Draining Well. Provided, however, whenever acreage is to be released from this Agreement pursuant to the provisions of this paragraph, the acreage to be released will not exceed the minimum number of acres required to drill the offset well(s) and will consist only of the depths from the surface to the stratigraphic equivalent of the deepest depth that are affected by a drainage concern or demand. If acreage is required to be released from this Agreement, Farmee will provide ExxonMobil with an executed, recordable release instrument, acceptable to ExxonMobil, within ten (10) days after ExxonMobil's request. After the applicable acreage is released from this Agreement, ExxonMobil will have the exclusive right to such released acreage, including the right to explore, develop and produce the acreage.

11.03. Disposal of Wastes. Farmee will store, handle, transport, and dispose of or discharge all material, substances, and wastes from the Farmout Area (including produced water, drilling fluids, and other wastes), whether present before or after the Effective Date, in accordance with applicable local, state, and federal laws and regulations, including Environmental Laws. Farmee will keep records as to the types, amounts, and location of materials, substances, and

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wastes that are stored, handled, transported, disposed of, discharged, or released onsite and offsite of the Farmout Area to the extent required by applicable laws and regulations. Within thirty (30) days of ExxonMobil's written request, Farmee will provide copies of all such records required herein evidencing Farmee's compliance.

ARTICLE 12

SURFACE USE

12.01. Surface Use Rights of ExxonMobil. ExxonMobil reserves the right of ingress and egress to and from the Farmout Area for the enjoyment of any rights reserved or retained by ExxonMobil. In addition to such rights, ExxonMobil reserves the right to have access to any part of the Farmout Area, including any Lease(s) conveyed hereunder, to conduct seismic, geophysical , and other investigations to obtain information regarding the Lease(s), including environmental assessments. Notwithstanding anything in this Agreement to the contrary, this paragraph will not operate to require ExxonMobil to provide any such information or data to Farmee or third parties.

12.02. Use of Roads or Canals. If Farmee contemplates the use of any of ExxonMobil's roads or canals, Farmee will advise ExxonMobil in writing and, if ExxonMobil consents to Farmee's use of any of ExxonMobil's roads or canals, Farmee and ExxonMobil will at that time enter into an agreement as to the terms and conditions for such use.

12.03. Surface Use and Restoration. Farmee will conduct its operations on the surface of the Farmout Area subject to the applicable contractual requirements and as would a prudent operator. Farmee will conduct its operations so as not to unreasonably interfere with ExxonMobil's operations . In accordance with the provisions of this Agreement, Farmee will restore the surface of any land that was affected by Farmee's or its Associated Parties' operations to, as near as reasonably practicable, the condition it was in prior to the Effective Date. Restoration of the surface will, at a minimum, require smoothing the surface of the ground surrounding abandoned well sites, filling any and all excavations, and clearing and removing any debris from the Farmout Area or any access route thereto and remediation of any contamination as required by Environmental Laws. Farmee will notify the surface owner(s) before conducting any operations on the surface of the Farmout Area and will provide the owner(s) with the name, address, and telephone numbers (working hours and emergency numbers) of Farmee's representative(s). Farmee agrees to make reasonable attempts to comply with requests by the surface owner(s) concerning the use of the surface of the Farmout Area as necessary or advisable to accommodate the requests of and maintain goodwill with the surface owner(s). Farmee will notify ExxonMobil in writing before Farmee plans to enter the Farmout Area.

Farmee will be responsible for settling or otherwise disposing of all Claims and Liabilities arising out of operations by Farmee or its Associated Parties on the surface of the Farmout Area. Farmee agrees to secure and furnish to ExxonMobil evidence of settlement for surface damages within one hundred twenty (120) days of the Completion or abandonment of any well drilled pursuant to this Agreement. If Farmee fails to timely furnish a written settlement with the surface owner(s), ExxonMobil will have the right, but not the obligation, to secure such settlement at Farmee's expense. If ExxonMobil deems Farmee's restoration of the premises to be inadequate, ExxonMobil may, at its sole discretion, perform or cause to be performed additional clean-up operations and Farmee agrees to reimburse ExxonMobil for all restoration­ related expenses incurred by ExxonMobil.

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12.04. Surface Use Agreements. Farmee shall provide ExxonMobil with copies of surface use, right-of-way, canal use, access, and any other agreements related and pertaining to Farmee's access to and use of the Farmout Area lands, whether said agreements pertain to the Farmout Area lands or to lands outside of the Farmout Area.

ARTICLE 13

PLUGGING AND ABANDONMENT OF WELLS; REMOVAL OF FACILITIES

Farmee will properly perform its obligations hereunder, including, but not limited to the following:

(a) plug, abandon, and re-abandon, if necessary, each Well drilled under this Agreement;

(b) remove all equipment and facilities, including flowlines and pipelines, placed on the Farmout Area;

(c) close all pits on the Farmout Area; and

(d) remediate the Farmout Area as required by Environmental Laws and any Related Agreements.

Farmee will pay all costs and expenses associated with the obligations assumed under this Article.

ARTICLE 14

COMPLIANCE WITH LAWS; RELEASE AND INDEMNITY

14.01. FARMEE WILL COMPLY WITH ALL VALID LOCAL, STATE AND FEDERAL LAWS, RULES AND REGULATIONS, INCLUDING BUT NOT LIMITED TO ENVIRONMENTAL LAWS.

14.02. FARMEE ACKNOWLEDGES THAT THE FARMOUT AREA MAY HAVE BEEN USED FOR OIL AND GAS OPERATIONS IN THE PAST. FARMEE AGREES THAT ANY CONVEYANCE GRANTED HEREUNDER WILL BE ON AN "AS IS" BASIS.

14.03. FARMEE WILL RELEASE, DEFEND, INDEMNIFY AND HOLD EXXONMOBIL AND ITS ASSOCIATED PARTIES HARMLESS FROM ANY AND ALL CLAIMS ARISING, ASSERTED, COMMENCED OR MADE ON OR AFTER THE EFFECTIVE DATE OF THIS AGREEMENT THAT RESULT FROM FARMEE'S ACTS AND OMISSIONS {OR THOSE OF ITS ASSOCIATED PARTIES) IN CARRYING OUT OPERATIONS UNDER THIS AGREEMENT AND/OR ON THE FARMOUT AREA. THE ABOVE CLAIMS WILL INCLUDE, BUT NOT BE LIMITED TO, THOSE ASSERTED OR BROUGHT BY ANY PARTY (INCLUDING, WITHOUT LIMITATION, FARMEE'S OR EXXONMOBIL'S EMPLOYEES, CONTRACTORS, ANY LANDOWNERS OR INDIVIDUALS, LOCAL, STATE OR FEDERAL GOVERNMENTAL BODY OR AGENCY) FOR DEATH, PERSONAL INJURY, DAMAGE TO THE FARMOUT AREA OR NATURAL RESOURCES, AND/OR FAILURE TO COMPLY WITH THE EXPRESS OR IMPLIED TERMS OF A MINERAL LEASE OR ANY OTHER CONTRACTUAL REQUIREMENTS. SUCH CLAIMS WILL ALSO INCLUDE ANY THAT ARISE OUT OF THE PLUGGING AND

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ABANDONING OR FAILURE TO PLUG AND ABANDON ANY WELLS ON OR IN THE FARMOUT AREA (WHETHER PLUGGED AND ABANDONED PRIOR TO OR AFTER THE EFFECTIVE DATE OF THIS AGREEMENT) OR ARISING OUT OF THE REMOVAL OF OR FAILURE TO REMOVE ANY PIPELINE OR OTHER FACILITIES OR ON ACCOUNT OF THE PRESENCE, DISPOSAL, AND/OR RELEASE OF ANY MATERIAL OF ANY KIND IN, ON, OR UNDER THE FARMOUT AREA COVERED HEREBY (WHETHER OR NOT SUCH MATERIAL WAS PRESENT PRIOR TO THE EFFECTIVE DATE OF THIS AGREEMENT) OR CLAIMS ARISING FROM OR PURSUANT TO ENVIRONMENTAL LAWS.

THE TERMS OF THIS ARTICLE 14 WILL APPLY NOTWITHSTANDING THE STRICT LIABILITY, NEGLIGENCE, JOINT NEGLIGENCE OR FAULT OF EXXONMOBIL OR ANY PARTY OR PARTIES. THE PROVISIONS SET FORTH IN THIS ARTICLE 14.01, 14.02, & 14.03 WILL SURVIVE TERMINATION OF THIS AGREEMENT.

ARTICLE 15

RELATED AGREEMENTS; THIRD PARTY NOTIFICATIONS AND APPROVALS

15.01. Related Agreements . Except as expressly otherwise provided herein, this Agreement is subject to all Related Agreements. Farmee will assume all of ExxonMobil's obligations and Liabilities under the Related Agreements, including compliance with express and implied covenants, insofar as these obligations and Liabilities pertain to the Farmout Area, and Farmee will execute all documents necessary to effectuate such assumption of ExxonMobil's obligations and Liabilities. This Article applies to all Related Agreements, whether or not Farmee has actual or constructive notice of such Related Agreements. 15.02. Third Party Notifications and Approvals. The rights of Farmee under this Agreement may require notification to or approval/consent by lessors, joint interest owners, farmers, sublessors, assignors, granters, governmental bodies having jurisdiction, and other third parties, and Farmee will be solely responsible for giving all such notifications and obtaining all such approvals and consents. If any part of the Farmout Area is subject to an operating agreement to which ExxonMobil is a party, Farmee is responsible for the following, as necessary:

(a) obtaining approval from the operator and working interest owners to transfer the working interest and obligations under each operating agreement or plan of unitization covering an interest in the Farmout Area; and

(b) for ExxonMobil-operated Properties (if ExxonMobil does not elect to ballot the parties), balloting the parties to each applicable operating agreement or plan of unitization to select a successor operator.

EXXONMOBIL AND ITS ASSOCIATED PARTIES WILL NOT BE LIABLE FOR ANY RISK, LOSS, EXPENSE OR CLAIMS FARMEE MAY SUFFER AS A RESULT OF FARMEE'S FAILURE TO PROVIDE ANY OF THE NOTIFICATIONS REFERENCED IN THIS ARTICLE 15.02, OR ITS FAILURE OR INABILITY TO SECURE ANY OF THE APPROVALS AND CONSENTS REFERENCED IN THIS ARTICLE 15.02. IT IS HEREBY UNDERSTOOD AND AGREED THAT FARMEE WILL DEFEND AND INDEMNIFY EXXONMOBIL AND ITS ASSOCIATED PARTIES FROM ANY AND ALL CLAIMS ARISING OUT OF ANY FAILURE TO PROVIDE SUCH NOTIFICATIONS OR OBTAIN SUCH APPROVALS OF CONSENTS, AND FOR ANY FAILURE TO SECURE WAIVERS OF MAINTENANCE OF UNIFORM INTEREST OR PREFERENTIAL RIGHTS TO PURCHASE UNDER ANY APPLICABLE AGREEMENTS. SUCH INDEMNITY WILL APPLY NOTWITHSTANDING THE NEGLIGENCE OF ANY PARTY OR

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PARTIES, INCLUDING EXXONMOBIL AND ITS ASSOCIATED PARTIES. THIS PROVISION WILL SURVIVE TERMINATION OF THIS AGREEMENT.

ARTICLE 16

COMMUNICATIONS

Unless otherwise provided in this Agreement, communications, including notices, under this Agreement that must be in writing and received by a specified date will be deemed to have been made when actually received, whether delivered by courier, received by confirmed facsimile transmission, or delivered by the U.S. Mail, as follows:

EXXONMOBIL FARMEE

ExxonMobil Production Company LLOLA, L.L.C. Attn: Regional Land Manager Attn: President P.O. Box 4610 1001 Ochsner Blvd., Ste. A Houston, Texas 77210-4610 Covington , LA 70433

Physical Address: 22777 Springwoods Village Parkway Spring, Texas 77389

Each Party hereto may change its address, notice recipient, and facsimile number set forth above by giving notice of the change in accordance with this Article. If Farmee assigns a portion of its interest hereunder, Farmee and its assignee(s) will designate one Party as the Party to receive, on behalf of Farmee and its assignee(s), the communications required hereunder. ExxonMobil will be required to send and make communications with only the designated Party.

ARTICLE 17

RENTAL, SHUT-IN, AND MINIMUM ROYALTY PAYMENTS

17.01. Responsibility for Making Payments. ExxonMobil shall have the right, but not the obligation, to make rental, shut-in, minimum royalty payments, and other payments that are necessary to maintain the Lease(s).

17.02. Farmee's Obligation to Reimburse ExxonMobil. Farmee will reimburse ExxonMobil for the full amount of any payment made pursuant to this Article 17 within thirty (30) days of receipt of an invoice from ExxonMobil, provided that if any delay rental, minimum royalty, or shut-in Gas Well payment will serve to maintain acreage not included in any applicable Conveyance made pursuant to this Agreement, then Farmee's reimbursement will be proportionately reduced on an acreage basis; however, no reduction will be made by reason of any applicable depth limitation. If reimbursement is not made within such 30-day period, the unpaid balance will bear interest monthly at the Agreed Interest Rate. ExxonMobil will not be liable for any inadvertent error or failure with respect to such payments.

17.03. Notification of Shutting-In of Well. If Farmee contemplates that: 1) Farmee will Complete a Producer and then shut-in the well; or 2) Farmee will shut-in a well that is producing

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oil or gas, Farmee will give ExxonMobil immediate notice of Farmee's intention to shut-in the well and the reasons for the proposed shu t-in.

17.04. [Intentionally Deleted)

It is expressly understood and agreed that the terms of this Article 17 will not apply to oil and gas leases granted under this Agreement covering ExxonMobil mineral fee.

ARTICLE 18

NOTIFICATION OF CESSATION; OPTIONAL RIGHT TO REASSIGNMENT

18.01. Cessation of Production.

(a) If Farmee earns a Conveyance pursuant to the terms of this Agreement, Farmee will covenant to use its best efforts to maintain the Earned Interests in force by production in paying quantities or drilling or reworking operations. ExxonMobil reserves the optional right to a reassignment in the event Farmee decides to surrender or abandon the Earned Interests or production ceases on the Earned Interests for a period in excess of sixty (60) consecutive days. If production ceases on the Earned Interests for a period in excess of sixty (60) consecutive days, Farmee will give ExxonMobil immediate written notice thereof along with Farmee's plans, if any, to maintain any Lease(s). If Farmee intends to surrender any Lease(s), Farmee will give ExxonMobil at least thirty (30) days prior written notice of such intention. If Farmee elects to abandon (which term will be defined in this provision as failure to attempt to restore production, whether by drilling or workover operations or other means commenced within sixty (60) days from cessation of production) any Lease(s), Farmee will give ExxonMobil immediate written notice thereof. In either case, ExxonMobil will have the optional right, but not the obligation, for a period of ninety (90) days from receipt of notice to instruct Farmee to make a reassignment of such Lease(s), or portion thereof, that ExxonMobil desires to have reassigned.

(b) In addition to the right of reassignment set forth in subparagraph (a) above, in the event: 1) production in paying quantities ceases from any formation(s) or zone(s) within an Earned Interest for a period of one hundred eighty (180) consecutive days during which Farmee does not conduct operations to restore such production from such formation(s) or zone(s), or if such operations are conducted but fail to restore such production; and 2) the applicable Earned Interest is being otherwise maintained by production or operations at shallower depths, then Farmee will immediately notify ExxonMobil and ExxonMobil will have the optional right, but not the obligation, for a period of ninety (90) days, to instruct Farmee to make a reassignment (or release, if an oil and gas lease on ExxonMobil mineral fee) of said Earned Interest as to all depths below the base of the stratigraphic equivalent of the deepest formation or zone which is being maintained by production or operations.

18.02. Reassignment. If ExxonMobil does require Farmee to make a reassignment (or release, if an oil and gas lease on ExxonMobil mineral fee), Farmee will furnish ExxonMobil with the reassignment within thirty (30) days from receipt of ExxonMobil's written request. The reassignment will be in a form acceptable to ExxonMobil, free and clear of all lease burdens,

18 EM Contract No. 6008015

overriding royalties, and payments out of production in excess of or in addition to those existing as of the Effective Date and will contain a description of the interest to be reassigned and a special warranty of title provision. The reassignment will include only the Leases, Wells, equipment, facilities, including pipelines and flowlines, and pits that ExxonMobil designates in writing to have included in the interests to be reassigned to ExxonMobil. If Farmee and its assignees fail to make the reassignment within thirty (30) days of ExxonMobil's written request or if Farmee or Farmee's assignees cannot be located by ExxonMobil, ExxonMobil may file a reassignment of record, and such reassignment will convey the Earned Interests, or portion thereof, to ExxonMobil with the same result as if the reassignment was executed by Farmee and its assignees.

After the date of the reassignment to ExxonMobi,l Farmee will remain responsible for the obligations in Article 13 above, except for any obligations that are associated with the Wells, equipment, facilities, including pipelines and flowlines, and pits that are included in the reassignment to ExxonMobil. Farmee agrees to fulfill its obligations under Article 13 as soon as practicable, but no later than ninety (90) days after the date that ExxonMobil requests a reassignment.

ExxonMobil's decision not to exercise its optional right to reassignment or to request a release will not result in liability to ExxonMobil for any reason.

ARTICLE 19

TAXES

Farmee will pay all production and severance taxes assessed against its share of production. Farmee will pay all ad valorem taxes assessed against interest that is the subject of a Conveyance hereunder, provided that such ad valorem taxes will be prorated between the Parties for the year in which the Conveyance is effective and in the year of any release or reversion. Any increase in ad valorem taxes assessed against any interest that is the subject of a Conveyance hereunder as a result of Earning Wells will be for Farmee's account.

ARTICLE 20

TITLE MATTERS

ExxonMobil in no way warrants or represents the number of acres or ExxonMobil's interest in the Farmout Area or any other matter relating to title. Farmee acknowledges that ExxonMobil has made no representations as to the number of acres or ExxonMobil's interests covered by this Agreement.

Farmee will furnish ExxonMobil with copies of any title examination conducted and title curative materials acquired by Farmee on the Farmout Area within fifteen (15) days of the date that the materials become available to Farmee.

Farmee will not seek to obtain any title instruments, including but not limited to oil and gas leases, that would place a cloud on ExxonMobil's ownership in the Farmout Area without ExxonMobil's prior written consent, which consent will not be unreasonably withheld.

ARTICLE 21

EXCLUSIONS

19 EM Contract No. 6008015

This Agreement is intended to commit to Farmee only the rights specifically described in this Agreement. Notwithstanding anything in this Agreement to the contrary, it is expressly understood and agreed that this Agreement will not cover, and ExxonMobil will not be deemed to have conveyed or have any obligation to convey: 1) any well located on or in the Farmout Area that is producing or capable of producing oil and/or gas, including all personal property associated with or used in connection with any such Well, including, but not limited to, casing, tubing, surface equipment, tanks, pipelines, compressors, and all other associated personal property; 2) any rights to production from any such Well; and 3) any interest in the Lease(s) to which production from any such Well is attributed.

ARTICLE 22

DEFAULT; TERMINATION

In the event of Farmee's failure or default in: 1) the commencement and drilling of the Initial Well, the Substitute Well, or the Additional Well(s), if any, in the time and manner herein provided; 2) the making of reports and/or in the furnishing of information, logs, surveys, or other data herein required; or 3) any of the other requirements, conditions, or obligations as herein set forth, then ExxonMobil will be relieved of the obligation to make any Conveyance, other than any Conveyance already earned by Farmee under the terms hereof, and ExxonMobil may, at ExxonMobil's option, terminate this Agreement by sending written notice to Farmee. Provided, however, in the event Farmee fails to timely commence Actual Drilling Operations of any well pursuant to this Agreement, no such written notice of termination will be necessary and Farmee will have no right to remedy its default or earn the interests in the Farmout Area.

Upon the full or partial termination of this Agreement, all of ExxonMobil's obligations under this Agreement, as to the released acreage or as to all acreage if this Agreement is terminated in its entirety, will terminate except as to the interests in the Farmout Area or portions thereof already conveyed or earned hereunder. Upon the full or partial termination of this Agreement, all of Farmee's rights, titles, and interests under this Agreement, as to the released acreage or as to all acreage if this Agreement is terminated in its entirety, will terminate except as to the interests in the Farmout Area, or portions thereof, already conveyed or earned hereunder. ExxonMobil's right of termination as herein set forth will be in addition and without prejudice to any other rights or causes of action which ExxonMobil may have, either at law or in equity, arising out of Farmee's failure or default hereunder.

Farmee agrees to fulfill its obligations under Article 13 as soon as reasonable, but no later than ninety (90) days after the date that this Agreement is terminated.

ARTICLE 23

ASSIGNMENT

This Agreement is not assignable or delegable by Farmee in whole or in part, and any attempted assignment or delegation by Farmee will be void, unless ExxonMobil has given its prior written consent. No assignment will relieve Farmee of its obligations under this Agreement, including those obligations associated with any interest that is assigned. Consent by ExxonMobil

20 EM Contract No. 6008015

to any such assignment will not relieve Farmee or any assignee from the rights and obligations as to any future assignment or from the timely and proper performance of any of Farmee's obligations hereunder.

ExxonMobil will have the right to withhold its consent to any proposed assignment if it determines, in good faith, that adequate protections do not exist to guarantee the proper and timely performance of all of Farmee's obligations hereunder. Upon request, ExxonMobil will be provided with sufficient information to permit it to evaluate the financial responsibility of any proposed third party assignee.

If Farmee contemplates an assignment to another party or parties, Farmee will give prompt notice to ExxonMobil, addressed to the Assignment Notice Recipient (see Exhibit "5"), of the proposed assignment. If ExxonMobil consents to the assignment, it will not be effective until ExxonMobil has received a fully executed and recorded copy of the conveyance evidencing Farmee and its assignee's willingness to be bound by all of the terms and conditions of this Agreement.

Notwithstanding anything in this Agreement to the contrary, ExxonMobil will have the right, in ExxonMobil's sole discretion, to assign to any affiliate or subsidiary or to any third party, from time to time and in whole or in part, ExxonMobil's rights hereunder. ExxonMobil's rights will include, but not be limited to, any right and option ExxonMobil may have to purchase the oil or gas as provided for in this Agreement. If ExxonMobil has reserved a right to purchase oil produced from the Farmout Area, no assignment will affect the price at which oil may be purchased hereunder and the price will continue to be governed by the provisions of this Agreement relating thereto.

ARTICLE 24

FINANCIAL STATEMENTS; SECURITY

24.01. Financial Statements. At the written request of ExxonMobil, Farmee agrees to provide ExxonMobil with the annual or interim financials for Farmee and its Affiliate_s. Any such annual or interim financial statements will be sent directly to ExxonMobil's Treasurer's department to the address noted below and such information provided will be held in strict confidence by the credit personnel of ExxonMobil's Treasurer's department:

ExxonMobil Upstream Treasurer's - Credit Attn: Credit Manager 22777 Springwoods Village Pkwy Spring, TX 77389

24.02. Provision for Well Plugging Bond or Letter of Credit. Prior to the commencement of Actual Drilling Operations for any well drilled under this Agreement, Farmee agrees to provide ExxonMobil with a Well Plugging Bond or Letter of Credit in the amount of Two Hundred Fifty Thousand and 00/100 Dollars ($ 250,000.00) to cover the costs of plugging and abandoning said well and restoring the surface in accordance with the provisions of this Agreement. Said Bond or Letter of Credit will be with a surety acceptable to ExxonMobil. Farmee may cancel the Bond or Letter of Credit when the subject well has been plugged and abandoned and the surface restored to the satisfaction of ExxonMobil in accordance with the provisions of this Agreement.

21 EM Contract No. 6008015

24.03. Additional Security. ExxonMobil will have the right to require Adequate Assurance of Performance. "Adequate Assurance of Performance" will mean sufficient security in the form, amount, and for the term reasonably acceptable to ExxonMobil, including, but not limited to, a standby irrevocable letter of credit or guaranty and/or a performance bond (including the issuer of any such security). The determination for the need of Adequate Assurance of Performance will be at ExxonMobil's sole discretion and will be based on ExxonMobil's customary practice of assessing a need for financial security from third party companies.

If ExxonMobil requires such Adequate Assurance of Performance, Farmee will deliver appropriate evidence of the security prior to conducting further operations on the Farmout Area. ExxonMobil will have the right to terminate this Agreement if Farmee fails to provide the required financial security within thirty (30) days of ExxonMobil's request.

ARTICLE 25

MINIMUM INSURANCE REQUIREMENTS

Farmee will carry and maintain in force the following insurance covering Farmee's liability hereunder, and furnish ExxonMobil, upon request, with certificates evidencing such coverage to ExxonMobil's Insurance Notice Recipient (see Exhibit "5"):

25.01. Workers' Compensation and Employers' Liability. For all Farmee's employees, workers' compensation and employers' liability insurance or similar social insurance in accordance with law which may be applicable to those employees.

25.02. Comprehensive General Liability. Comprehensive general liability insurance coverage and policy limits providing at least One Million Dollars ($1,000,000.00) coverage for injury, death, or property damage resulting from each occurrence.

25.03. Automobile Liability. Automobile liability insurance coverage and policy limits covering owned, non-owned and rented automotive equipment providing at least One Million Dollars ($1,000,000.00) coverage for injury, death, or property damage resulting from each accident.

The minimum insurance requirements as set forth above will not limit or diminish in any way the respective rights and obligations of the Parties.

ARTICLE 26

ALTERNATE DISPUTE RESOLUTION AND ARBITRATION

26.01. General.

(a) This Article 26 applies to any dispute between the Parties, arising at any time, related to, or arising out of, this Agreement. Whether a dispute is related to or

22 EM Contract No. 6008015

arises out of this Agreement are issues that will be resolved under the alternate dispute resolution and arbitration provisions of this Article.

(b) As to the disputes subject to this Article, any Claim or controversy of whatever nature, including an action in tort or contract or a statutory action ("Disputed Claim"), or the arbitrability of a Disputed Claim, will be resolved under the terms, condit ions, and procedures set forth in this Article and will be binding on both Parties and their respective successors and assigns. Neither Party may prosecute or commence any suit or action against the other Party relating to any matters that are subject to this Article, except as provided in this Article.

26.02. Negotiations . The Parties agree to attempt to resolve any dispute arising out of or relating to this Agreement through negotiation. Within thirty (30) days after one Party gives the other Party written notice describing the dispute and requesting negotiations, representatives of the Parties with authority to resolve the dispute will meet at a mutually agreed upon location to attempt to resolve the dispute. Negotiations will continue until the Parties have resolved the dispute or until one of the Parties gives written notice that it will no longer continue to negotiate. If, for any reason, the Parties' representatives fail to meet within the thirty (30) day deadline or if a Party gives written notice that it is no longer willing to continue negotiations, either Party may commence binding arbitration of the dispute pursuant to Article 26.03.

26.03. Arbitration. Any dispute arising out of or relating to this Agreement that the Parties fail to resolve by negotiation as set forth in Article 26.02 will be resolved by arbitration before three arbitrators pursuant to the CPR Institute for Dispute Resolution Rules for Non-Administered Arbitration as modified herein. Each Party will appoint one arbitrator as provided in CPR Rules 3.3 and 3.5, and the two arbitrators so appointed will appoint the third, who will chair the tribunal, selected as provided in CPR Rule 5.2. The place of arbitration will be Houston, Texas. The arbitrators will apply the substantive law of Texas to the merits of the dispute, except that the arbitrators will not apply any choice of law rules that would call for the application of the substantive law of any other jurisdiction. The Federal Arbitration Act will apply to the arbitration . The arbit rators' award will be final and binding on the Parties. Judgment on the award may be entered in any court of competent jurisdiction.

ARTICLE 27

MISCELLANEOUS

27.01. Entire Agreement. This Agreement constitutes the entire agreement between the Parties as to the transaction contemplated hereby. All previous negotiations and communications between the Parties as to these matters are merged into this Agreement.

27.02. Amendment; Survival. This Agreement will be binding on and inures to the benefit of the Parties and their heirs, assigns, and successors and the terms hereof will constitute covenants running with the land. This Agreement may be supplemented, altered, amended , modified, or revoked in writing only, signed by the Parties. Each obligation under this Agreement that cannot be performed before termination of this Agreement or release of acreage from this Agreement will survive termination of this Agreement or release of acreage from this Agreement.

27.03. Choice of Law. This Agreement and its performance will be construed in accordance with, and governed by, the internal laws of the State of Louisiana, without regard to the choice of law rules of any jurisdiction, including Texas.

23 EM Contract No. 6008015

27.04. Headings. The headings in this Agreement are for guidance and convenience of reference only and do not limit or otherwise affect or interpret any terms or provisions of this Agreement.

27.05. No Admission. No part of this Agreement, no performance under this Agreement, and no payment of any amount in accordance with any provision of this Agreement will constitute or be construed as a finding, evidence, admission, or acknowledgment of any liability, fault, or past or present wrongdoing, or violation of any law, rule, regulation, or policy by ExxonMobil or Farmee or by their respective Associated Parties.

27.06. No Third Party Beneficiaries. Nothing in this Agreement entitles any party other than ExxonMobil and Farmee to any claim, cause of action, remedy, or right of any kind. There are no third party beneficiaries of this Agreement.

27.07. Farmout Well Names and Press Releases. Except in cases when such use is expressly required by applicable law, Farmee agrees that it will not use the ExxonMobil name in any form in any press release or release of information to the public regarding the operations hereunder or in the names of any wells drilled hereunder without the express prior written consent of ExxonMobil.

27.08. Severability. The provisions of this Agreement are severable. If any part of this Agreement is found by a court with jurisdiction to be void or invalid, the holding will not affect the other portions of this Agreement that can be given effect without the invalid or void portion.

27.09. EXPRESS NEGLIGENCE RULE: CONSPICUOUSNESS. FARMEE ACKNOWLEDGES THAT THE ARTICLES OF THIS AGREEMENT SET OUT IN BOLD CAPITAL LETTERS SATISFY THE REQUIREMENTS OF THE EXPRESS NEGLIGENCE RULE AND/OR ARE CONSPICUOUS.

27.10. Exhibits. All exhibits referenced in and attached to this Agreement are incorporated into it. If the terms and provisions of the body of this Agreement conflict with the exhibits to this Agreement, the terms and provisions of the body of this Agreement will supersede the conflicting provisions in the exhibits.

27.11. Setoff. For purposes of this prov1s1on only, ExxonMobil and Farmee will be deemed to include such companies' respective subsidiaries and affiliates. ExxonMobil may setoff any amount owed to ExxonMobil by Farmee against any amount owed to Farmee by ExxonMobil, whether under this Agreement or any other agreement or arrangement between or among any of them. If any amount owed is unliquidated or unascertainable, ExxonMobil may setoff an amount estimated by it in good faith to be the amount owed.

27.12. Partnerships. It is not the intention of the Parties to create, nor will this Agreement be construed as creating, a mining or other partnership or association, or to render the Parties liable as partners.

27.13. Execution by the Parties. Neither the submission of this instrument, or any information concerning the Farmout Area, for examination nor negotiations between the Parties will constitute an offer to sell or an option for the Farmout Area. This instrument and the underlying transaction will become enforceable and binding only upon execution by the Parties and delivery

24 EM Contract No. 6008015

of the executed Agreement to ExxonMobil within fifteen (15) days of the Effective Date. Farmee represents that its duly authorized agent has executed this Agreement.

The Parties have executed triplicate originals of this Agreement on the dates below their signatures, to be effective as of the Effective Date.

LLOLA, L.L.C. Mobil Oil Exploration & Producing S) ]kL- Southeast,ui{,( Inc. /}

}1115 By: By: b,.,,J'&,' Name: David Mccann N ame: Jarod M. Rolland \ j()f \ Title: President Title: Agent and Attorney-in-Fact

Date: ;J; t'/2¾ ;Y/r Date: Ar"' ' z:s I 'Zol

25

EXHIBIT 1

Attached to and made a part of that certain Farmout Agreement dated March 23, 2018, by and between Mobil Oil Exploration and Producing Southeast, Inc., as Farmor, and LLOLA, L.L.C. as Farmee; ExxonMobil Contract No. 6008015.

Description of Farmout Area

The following lands in Plaquemines Parish, Louisiana:

EM FILE NO.: 3003871-001 GRANTOR: Atled Corporation GRANTEE: General Crude Oil Company DATE: April 23, 1968

PROPERTY DESCRIPTION

INSOFAR AND ONLY INSOFAR as the above covers 443.10 acres, more or less, within Sections 3, 4, 5, 8, and 9 Township 21 South - Range 20 East, Plaquemines Parish, Louisiana, as depicted within the outline shown on the plat attached hereto as Exhibit "1-A", LIMITED to the rights and depths in sections 3, 4, 8, and 9 from the surface down to the base of the 10,500' sand, being the stratigraphic equivalent of the sand seen between 9,553' and 9,726' measured depth in the electric log for the Texaco Delta Duck Club Unit #019 (Serial #32515). For further identification, the top of the 10,500' sand is also seen at 10,180 feet measured depth in the electric log for the Texaco Delta Duck Club Unit #016 (Serial # 32146).; and LIMITED to the rights and depths in section 5 from 9,767 feet below the surface down to the base of the 10,500' sand, being the stratigraphic equivalent of the sand seen between 9,553' and 9,726' measured depth in the electric log for the Texaco Delta Duck Club Unit #019 (Serial #32515). For further identification, the top of the 10,500' sand is also seen at 10,180 feet measured depth in the electric log for the Texaco Delta Duck Club Unit #016 (Serial# 32146).. The Farmout Area shall be revised to include the rights and depths in section 5 from the surface down to 9,767 feet below the surface if ExxonMobil is furnished a release of the expired lease from the lessee of record and covering said lands.

EXHIBIT 1-A

Attached to and made a part of that certain Farmout Agreement dated March 23, 2018, by and between Mobil Oil Exploration and Producing Southeast, Inc., as Farmar, and LLOLA, L.L.C. as Farmee; ExxonMobil Contract No. 6008015.

Plat of Farmout Area

..•..."'-7-" -:-· .. ­ . -.,,..v -- .-, .r.. r. . ,. ' - ,...... ,,...,..;: I ' ...... _.. . .,..,.;_ ..,..: _l;;. ; • ,j_ · \;i'i < .. . ,(/ { };} ' .-. - ,._ ...... • .-:...... -1 ,-.l, ... , ..._-, ...... -...- - JJ:,. .. ·. ,, ., '•'J :1' - ;f!' \,... ., ·-- . ..-.::,/ ::· j "'·{!it.t -, - ,.., 'fl -. · ,. • . ,, . r-h ,, 11·1 : ,_:.,·,.\·; ·· '••• ·•. ,◄ :.,-\S..E. G,.. ?f1o· N· 3 ,· . .,._ ,, • •-. " • ...,,.<" J ..,,I. -, • I :- , I - • 1 ''.}! / :- :- ._; :.;::r -,.. -t .:·' -· ·· .. -:i:,_, h1 .. · . : ·" :f' .. .,.,,..r - i...t"c ti'otl .,. . ...).• ,:- -.,.., ft. ·' ,'.',SECTI ON 5 • •• . •. '! •• --,:• 11., • . ;-t !, ..-;,..T•j • ,,/ - -. , ;' •:s,_;.· ,- ; ' _; 1-. :·"1. ;- ...... •, .. :-"•,- -.. '' •.--.•.. .:. '·x,-.-..- .::. / ··-i· · 1 (•y-: J -...... - •- -. •- , t• I , . ,: ; ;;' ' , ;;:::) ...... - >;< ,. :, ...... _.,..· ··• - -'-'---+ - -. ·- · ...; J! 't..ni\ .,, • ,., '"·•J•--v<'".·. ·,:·,•·.-s ·. .-.-.t - \ •:_ , '.-f•-- ;il •• · /, I ..• ;: : - SECTION ,'-i. . ' '·' - --,filf '.:ui,lk,,.; ;- •• :·; ' - ' • • • ' '•. • J ' ' ,, • - '/."- ' •• 1 .... i SECTION ·· 8 -.. l!ilallli -- ) r _:... ,...... •> :,·.. > i -- !i • ' - ...... ·.1 ·1.:,. - .?,;::y!P!\":1% ':e' :• ,;e;. r.""' ; f - -• l f \,..111,,•·.'i .-- . .; ··- - -:41 , f,, ·-:. D • ">,.•. i,1 j..;.,_1_, :.:-x J-..· !!IH .iA_'j::,. -- · _. -

0MB Control Number 1018-0162 1 Expiration Date: 11/30/2019

Oil and Gas Operations For Official Use Only: Special Use Permit Application Approved Permit #

Refuge Name: Delta National Wildlife Refuge Station #: I .------. I Permit Term: from I Address: 61389 Highway 434 Ito[

City: Lacombe LA._ 70445 State Zip Code

Attn: (Refuge Official) Jim Panaccione

Email: [email protected]

Phone#: (985) 882-2009

INSTRUCTIONS FOR COMPLETING APPLICATION

You may complete the application portion in person at the refuge office, verbally, or electronically and submit it to the refuge for review. If you have a question, contact the specific refuge headquarters office where you propose to conduct the activity to determine applicability of a particular item and how to comply with a particular information request. We may add special conditions or permit stipulations to permit prior to approval. Information for Part 1 (contact information) is required. Complete the other Parts of the form as they apply to your proposed activity as explained below. You do not need to resubmit information that is already on file with the Service, provided that such information is still current and accurate. You should reference this information in your oil and gas operations permit application.

You may submit documents and materials submitted to other Federal and State agencies noting how the information meets the specific requirements of the Operations Permit.

Type of Permit {identify the type of permit you are applying for (check all that apply):

0Temporary Access Permit - complete Parts 1 and 2.

[Z]operations Permit: all applicants must complete Parts 1, 3, 4, 8, 9, and 10. In addition, if you are proposing:

D Geophysical exploration - complete Part 5. Drilling operations- complete Part 6 I I D Production operations - complete Part 7 After you complete the application, sign the application and return it to the refuge.

SIGNATURES Sign, date, and print this fonn and return it to the refuge for processing.

I

Signature of Appli ca · ;,. £f't::_...-1 / "-. j Date of Application: !3 I i V I { 1 72·-.).,..., -z.. \ l\ \:\ --:,-!.. , ­ ofk -..),1:, •- j Hl \o.-.,--6. 7 FWS Form 3-2469 12/2016 0MB Control Number 1018-0162 2 Expiration Date: 11/30/2019

PART 1: CONTACT INFORMATION 1) Name of Applicant: -Ro- n-Ha-rv--e=y------2) Title: Operations Manager 3) Business Name: LLOX, L.L.C.

4 ) Str ee t Addr ess: 1001 Ochsner Blvd., Suite A

5) City/State/Zip: Covington/ LA/ 70433

985 2 76 5707 9 85 276 522 6) Business Phone#: ( ) - 7) Business Fax#: ( ) - 0 8) Email [email protected]

9) Provide the name of the operator, employee, agent, or contractor responsible for overall management of the proposed operations. Representative: Lee womack Matrix New World Engineering

10) Business Name:

11) Street Address: 2798 O'Neal Lane, Building F

12) City/State/Zip: Baton Rouge I LA / 70816

13) Bus.iness Phone#: (225) 292-3271 14) Business Fax#: 15) Emai:l Iwomack@mat·nxneworld.com

16) Required Documents • Documentation demonstrating the right to operate within the refuge.

Attached?{!)YesQ No Q Previously Provided: ______

PART 2: TEMPORARY ACCESS FOR RECONNAISSANCE SURVEYS (Provide information for items 17 through 20 on separate sheets and identify each response by number. For item 21, indicate below whether or not required document is attached. If the document was previously provided, indicate date and other specifics.)

17) List names, addresses, phone numbers and job title/qualifications of all specialists responsible for conducting the reconnaissance surveys (Only required if the assistants/subcontractors/subpermittees will be operating on the refuge without the pennittee being present.)

18) Briefly describe the intended operation so that we can determine reconnaissance survey needs.

19) Describe the survey methods you intend to use to identify the natural and cultural resources.

20) Describe proposed means of access and routes proposed for conducting the reconnaissance surveys.

21) Required Documents • Location map (to-scale and determined by us as acceptable) delineating the proposed reconnaissance survey area in relation to the refuge boundary and the proposed area of operations attached?

Attached?QYes {!)No QPreviously Provided: ______

FWS Form 3-2469 12/2016 0MB Control Number 1018-0162 3 Expiration Date: 11/30/2019

PART 3: EXISTING CONDITIONS FOR YOUR AREA OF OPERATIONS (All applicants applying for an operations permit must complete this part. Provide information for items 22 through 25 on separate sheets and identify each response by number.)

22) Describe the natural features including streams, lakes, ponds, wetlands, topographic relief, and areas the Service has indicated to you are sensitive.

23) Describe the locations of existing roads, trails, railroad tracks, pipeline right-of-ways, pads, and other disturbed areas.

24) Describe the locations of existing structures that your operations could affect, including buildings, pipelines, producing oil and gas wells, freshwater wells, underground and overhead electrical lines, and other utility lines.

25) Describe the natural resource and cultural resource survey reports for your proposed area of operations.

PART 4: PROPOSED NEW SURFACE USES (All applicants applying for an operations permit must complete this part. Provide information for items 26 through 32 on separate sheets and identify each response by number. For item 33, indicate below whether or not required documents are attached. If a document was previously provided, indicate date and other specifics.)

26) Describe and show the method and diagrams, including cross-sections, of any proposed pad construction, road construction, cut­ and-fill areas, erosion control, and surface maintenance.

27) Describe the number and types of equipment and vehicles, including an estimate of vehicular round trips associated with each phase of operation.

28) Describe the estimated timetable for each phase of the proposed operations, including any operational timing constraints.

29) Describe the type and extent of security measures proposed at your area of operation.

30) Describe the power sources and their transmission systems for the proposed operations.

31) Describe the types and quantities of all solid and liquid waste generated and the proposed methods of storage, handling, and disposal.

32) Describe the source, quantity, access route, and transportation/conveyance method for all water to be used in operations; and estimations of any anticipated waste water volumes generated and how they will be managed and disposed of.

33) Required Documents: • Location map (to-scale and determined by us as acceptable) identifying the proposed area of operations, existing conditions (as described in Part 3), and proposed new surface uses that clearly identifies the boundaries of each of your mineral tract(s) in relation to your proposed operations and the relevant refuge boundary. Attached?@Yes QNo Q Previously Provided:

• Location map (to-scale and determined by us as acceptable) showing proposed access routes of new surface disturbances as determined by a location survey.

Attached?@Yes Q No Q Previously Provided: ______

• Location map (to-scale and determined by us as acceptable) showing the proposed location of all support facilities, including those for transportation (e.g., vehicle parking areas, helicopter pads), sanitation, occupation, staging areas, fuel storage areas, refueling areas, loading docks, water supplies, and disposal facilities). Attached?@Yes QNo Q Previously Provided: ______

FWS Form 3-2469 12/2016 0MB Control Number 1018-0162 4 Expiration Date: 11/30/2019

PART 5: GEOPHYSICAL EXPLORATION (Only applicants proposing to conduct geophysical exploration must complete this part. Provide information for items 34 through 37 on separate sheets and identify each response by number. For item 38, indicate below whether or not required document is attached. If the document was previously provided, indicate date and other specifics.)

34) Describe the number of crews and numbers of workers in each crew.

35) Describe the acquisition methods, including the procedures, specific equipment you will use, and energy sources (e.g., explosives, vibroseis trucks).

36) Describe methods of access along each survey line for personnel, materials, and equipment.

37) List of all explosives, blasting equipment, chemicals, and fuels you will use in the proposed operations, including a description of proposed disposal methods, transportation methods, safety measures, and storage facilities.

38) Required Documents: • Map (to-scale and determined by us to be acceptable) showing the positions of each survey line including all source and receiver locations as determined by a locational survey, and including shot point offset distances from wells, buildings, other infrastructure, cultural resources, and environmentally sensitive areas.

Attached?QYes @No Q Previously Provided: _

PART 6: DRILLING OPERATIONS (Only applicants proposing to conduct drilling operations must complete this part. Provide information for items 39 through 42 on separate sheets and identify each response by number.)

39) Describe the well pad construction, including dimensions and cross sections of: cut-and-fill areas and excavations for ditches, sumps, and spill control equipment or structures, including lined areas.

40) Describe the drill rig and equipment layout, including rig components, fuel tanks, testing equipment, support facilities, storage areas, and all other well-site equipment and facilities.

41) Describe the type and characteristics of the proposed drilling mud systems.

42) List the equipment, materials, and methods of surface operations associated with your drilling, well casing and cementing, well control, well evaluation and testing, well completion, well stimulation, and well plugging programs.

PART 7: PRODUCTION OPERATIONS (Only Applicants proposing to conduct production operations must complete this part. Provide information for items 43 through 47 on separate sheets and identify each response by number. For item 48, indicate below whether or not required documents are attached. If a document was previously provided, indicate date and other specifics.)

43) Provide the dimensions and the to-scale layout of the well pad, clearly identifying well locations, noting partial reclamation areas; gathering, separation, metering, and storage equipment; electrical lines; fences; spill control equipment or structures including lined areas, artificial lift equipment, tank batteries, treating and separating vessels, secondary or enhanced recovery facilities, water disposal facilities, gas compression and/or injection facilities; metering points; sales point (if on lease); tanker pickup points; gas compressor, including size and type (if applicable); and any other well site equipment.

44) Provide a general description of anticipated stimulations, servicing, and workovers.

45) Describe the procedures and equipment used to maintain well control.

46) Describe the method and means used to transport produced oil and gas, including vehicular transport; flowline and gathering line construction and operation, pipe size, and operating pressure; cathodic protection methods; surface equipment use; surface equipment location; maintenance procedures; maintenance schedules; pressure detection methods; and shutdown procedures.

FWS Form 3-2469 12/2016 0MB Control Number 1018-0162 5 Expiration Date: 11/30/2019

47) Describe the equipment, materials, and procedures proposed for well plugging.

48) Required Documents: • Road and well pad maintenance plan, including equipment and materials to maintain the road surface and control erosion.

Attached? Qves @No O Previously Provided: ______

• Vegetation management plan on well sites, roads, pipeline corridors, and other disturbed surface areas, including control of noxious or invasive species.

Attached? Qves (!) No O Previously Provided: ______

• Stormwater management plan for the well site

Attached?QYes @No O Previously Provided: ______

• Produced water storage and disposal plan.

Attached? Qves @No Q Previously Provided: ______

PART 8: MITIGATION ACTIONS AND ALTERNATIVES CONSIDERED (All applicants applying for an operations permit must complete this part. Provide information for items 49 through 51 on separate sheets and identify each response by number.)

49) Describe the steps you propose to take to mitigate anticipated adverse environmental impacts on refuge resources and uses, including but not limited to, the refuge's land features, land uses, fish and wildlife, vegetation, soils, surface and subsurface water resources, air quality, noise, lightscapes, viewsheds, cultural resources, and economic environment.

50) Describe any anticipated impacts that you cannot mitigate.

51) List alternatives considered that met the criteria of technologically feasible, least damaging methods of operations, as well as the costs and environmental effects of those alternatives.

PART 9: SPILL CONTROL AND EMERGENCY PREPAREDNESS PLAN (All applicants applying for an operations permit must complete this part. If you have a spill prevention control and countermeasure (SPCC) plan prepared under 40 CFR Part 112 that includes all the information required by this section, you may attach that plan to this application. Provide information for items 59 through 70 on separate sheets and identify each response by number.)

52) Spill, Fire, or Accident Company Representative: Floyd Lofton, Jr. Title: Rig Superintendent

53) Business Name : Coastal Drilling Company, L.L.C. (Rig 20)

54) Street Address: 5319 Port Road

55) City/State/Zip: New Iberia/ LA/ 70560

56) Emergency Contact Phone #: {337) 560-4446 57) Business Fax #: (337) 560-4469 58) Email:.______

59) Describe the notification procedures and steps taken to minimize damage in event of spill, fire, or accident.

60) Identify contaminating or toxic substances used within your area of operations or expected to be encountered during operations.

61) Provide a trajectory analysis for for potential spills not contained on location.

FWS Form 3-2469 12/2016 0MB Control Number 1018-0162 6 Expiration Date: 11/30/2019

62) Identify abnormal pressure, temperature, toxic gases or substances, or other hazardous conditions at your area of operations or expected to be encountered during operations.

63) Describe your measures (e.g., procedures, facility design, equipment, etc.) to minimize risks to human health, safety, and the environment.

64) Describe the steps to prevent accumulations of oil or other materials deemed to be fire hazards from occurring in the vicinity of well locations and lease tanks.

65) Describe the equipment and methods for containment and cleanup of contaminating substances, including a description of the equipment available at your area of operations and equipment available from local contractors.

66) Provide the storm water drainage plan and actions intended to mitigate stormwater runoff.

67) Provide the material safety data sheets for each material you will use/encounter during operations, including expected quantities maintained at your area of operations.

68) Describe the emergency actions you will take in the event of injury or death to fish and wildlife or vegetation.

69) Describe emergency actions you will take in the event of accidents causing human injury.

70) Provide the contingency plans for conditions and emergencies other than spills, such as if your area of operations is located in areas prone to hurricanes, flooding, tornados, fires, or earthquakes.

PART 10: RECLAMATION (All applicants applying for an operations permit must complete this part. Provide information for items 71 and 72 on separate sheets and identify each response by number.)

71) List the specific equipment, materials, methods, and schedule used to meet the operating standards for reclamation.

72) Provide an itemized list of the estimated costs that a third party would charge to complete reclamation.

Notice

In accordance with the Privacy Act (5 U.S.C. 552a) and the Paperwork Reduction Act (44 U.S.C. 3501), please note the following infonmation:

The issuance of a permit and collection of fees on lands of the National Wildlife Refuge System are authorized by the National Wildlife Refuge System Administration Act (16 U.S.C. 668dd-ee) as amended, and the Refuge Recreation Act (16 U.S.C. 460k-460k-4).

The infonmation that you provide is required to obtain or retain a benefit. We use the requested information to evaluate the qualifications, determine eligibility, and document penmit applicants under the above Acts. It is our policy not to use your name for any other purpose. We maintain the infonmation in accordance with the Privacy Act. We will consider all infonmation you provide in reviewing this application. False, fictitious, or fraudulent statements or representations made in the application may be grounds for revocation of the Special Use Penmit and may be punishable by fine or imprisonment (18 U.S.C. 1001). Failure to provide all required information is sufficient cause for the U.S. Fish and Wildlife Service to deny a penmit.

We also may make routine use disclosures: (a) to the U.S. Department of Justice when related to litigation or anticipated litigation; (b) of infonmation indicating a violation or potential violation of a statute, rule, order, or license to appropriate Federal, State, local, or foreign agencies responsible for investigating or prosecuting the violation or for enforcing or implementing the statute, rule, regulations, order, or license; (c) from the record of the individual in response to an inquiry from a Congressional office made at the request of the individual (42 FR 19083; April 11,1977); and (d) to provide addresses obtained from the Internal Revenue Service to debt collection agencies for purposes of locating a debtor to collect or compromise a Federal Claim against the debtor, or to consumer reporting agencies to prepare a commercial credit report for use by the Department of Justice (48 FR 54716; December 6, 1983).

An agency may not conduct or sponsor and a person is not required to respond to a collection of information unless it displays a currently valid 0MB control number. 0MB has approved this information collection and assigned control number 1018-0162. The public reporting burden for this infonmation collection varies based on the requested use. We estimate the relevant public reporting burden for the application for Temporary Access to average 17 hours per response. We estimate the time to complete an application for an Operations Permit will average 140 hours per response.

FWS Form 3-2469 12/2016 0MB Control Number 1018-0162 7 Expiration Date: 11/30/2019

These estimates include time for reviewing instructions, gathering and maintaining data, and completing and reviewing the form. You may send comments on this form or any aspect of this infonnation collection to the lnfonnation Collection Clearance Officer, U.S. Fish and Wildlife Service, 5275 Leesburg Pike, MS: BPHC, Falls Church, Virginia, 22041.

PERMIT CONDITIONS

The following tenns will be a part of your pennit.

General Terms and Conditions

1) You must comply with all operating standards in §§ 29.111 through 29.117, as well as with the standards in§§ 29.118 and 29.119, if applicable. These operating standards will be incorporated into the tenns and conditions of your operations pennit. Violation of these operating standards unless approved in your operations pennit will subject you to the PROHIBITED ACTS AND PENALTIES provisions of§§ 29.190 through 29.192.

2) You are responsible for ensuring that all of your contractors and subcontractors comply fully with the requirements of this subpart.

3) You may be required to reimburse the Service for the costs of processing and administering temporary access permits and operations permits.

4) You may not use any surface water or groundwater from a source located on a refuge unless you have demonstrated a right to use that water or the use has been approved by the Service.

5) You must provide the refuge an affidavit, signed by an official who is authorized to legally bind the company, stating that proposed operations are in compliance with all applicable Federal, State, and local laws and regulations and that all infonnation submitted to the Service is true and correct.

6) You agree to indemnify and hold harmless the United States and its officers and employees from and against any and all liability of any kind whatsoever arising out of or resulting from the acts or omissions of you and your employees, agents, representatives, contractors, and subcontractors in the conduct of activities under the operations permit.

7) You will be required to take all reasonable precautions to avoid, minimize, rectify, or reduce the overall impacts of your proposed oil and gas activities to the refuge. You may be required to mitigate for surface impacts and lost uses by providing for habitat creation, habitat restoration, land purchase, or other compensation agreed to by the Service.

8) You will be responsible for unanticipated and unauthorized damages as a direct or indirect result of your operations. You will be responsible for the actions and consequences of your employees and subcontractors. You will also be responsible for any reclamation of damages to refuge resources caused by your operations as a result of severe weather, fire, earthquakes, or the like thereof.

Other General Conditions and Requirements

1) Responsibility of Permittee: The pennittee, by operating on the premises, shall be considered to have accepted these premises with all facilities, fixtures, or improvements in their existing condition as of the date of this pennit. At the end of the period specified or upon earlier termination, the permittee shall give up the premises in as good order and condition as when received except for reasonable wear, tear, or damage occurring without fault or negligence. The permittee will fully repay the Service for any and all damage directly or indirectly resulting from negligence or failure on his/her part, and/or the part of anyone of his/her associates, to use reasonable care.

2) Operating Rules and Laws: The permittee shall keep the premises in a neat and orderly condition at all times, and shall comply with all municipal, county, and State laws applicable to the operations under the permit as well as all Federal laws, rules, and regulations governing national wildlife refuges and the area described in this permit. The permittee shall comply with all instructions applicable to this permit issued by the refuge official in charge. The permittee shall take all reasonable precautions to prevent the escape of fires and to suppress fires and shall render all reasonable assistance in the suppression of refuge fires.

3) Use Limitations: The permittee's use of the described premises is limited to the purposes herein specified and does not, unless provided for in this permit, allow him/her to restrict other authorized entry onto his/her area; and allows the U.S. Fish and Wildlife Service to carry on whatever activities are necessary for: (1) protection and maintenance of the premises and adjacent lands administered by the U.S. Fish and Wildlife Service; and (2) the management of wildlife and fish using the premises and other U.S. Fish and Wildlife Service lands.

4) Transfer of Privileges: This pennit is not transferable, and no privileges herein mentioned may be sublet or made available to any person or interest not mentioned in this permit. No interest hereunder may accrue through lien or be transferred to a third party without the approval of the U.S. Fish and Wildlife Service and the pennit shall not be used for speculative purposes.

FWS Form 3-2469 12/2016 0MB Control Number 1018-0162 8 Expiration Date: 11/30/2019

5) Compliance: The U.S. Fish and Wildlife Service's failure to require strict compliance with any of this permit's terms, conditions, and requirements shall not constitute a waiver or be considered as a giving up of the U.S, Fish and Wildlife Service's right to thereafter enforce any of the permit's terms or conditions.

6) Conditions of Permit not Fulfilled: If the permittee fails to fulfill any of the conditions and requirements set forth herein, the U.S. Fish and Wildlife Service shall retain all money posted under this permit to be used to satisfy as much of the permittee's obligation as possible.

7) Permit Payments: All payment shall be made on or before the due date to the local representative of the U.S. Fish and Wildlife Service by a postal money order or check made payable to the U.S. Fish and Wildlife Service.

8) Termination Policy: At the termination of this permit the permittee shall immediately give up possession to the U.S. Fish and Wildlife Service representative, reserving, however, the rights specified in paragraph 11 below. If he/she fails to do so, he/she will pay the U.S. Fish and Wildlife Service, as liquidated damages, an amount double the rate specified in this permit for the entire time possession is withheld. Upon yielding possession, the permittee will still be allowed to reenter as needed to remove his/her property as stated in paragraph 11 below. The acceptance of any fee for the liquidated damages or any other act of administration relating to the continued tenancy is not to be considered as an affirmation of the permittee's action nor shall it operate as a waiver of the U.S. Fish and Wildlife Service's right to terminate or cancel the permit for the breach of any specified condition or requirement.

9) Revocation Policy: The U.S. Fish and Wildlife Service may revoke this permit without notice for noncompliance with the terms hereof, or for violation of general and/or specific laws or regulations governing national wildlife refuges or other applicable laws, namely the Endangered Species Act.

10) Damages: The U.S. Fish and Wildlife Service shall not be responsible for: any loss or damage to property including but not limited to crops, animals, and machinery; injury to the permittee or his/her relatives or to the officers, agents, employees, or any other(s) who are instructed to be on the premises; the sufferance from wildlife or employees or representatives of the U.S. Fish and Wildlife Service carrying out their official responsibilities. The permittee agrees to hold the U.S. Fish and Wildlife Service harmless from any and all claims for damages or losses that may arise to be incident to the flooding of the premises resulting from any associated government river and harbor, flood control, reclamation, or Tennessee Valley Authority activity.

11) Removal of Permittee's Property: Upon the expiration or termination of this permit, if all rental charges and/or damage claims due to the U.S. Fish and Wildlife Service have been paid, the permittee may, within a reasonable period as stated in the permit or as determined by the U.S. Fish and Wildlife Service official in charge, but not to exceed 60 days, remove all structures, machinery, and/or equipment, etc., from the premises for which he/she is responsible. Within this period the permittee also must remove any other of his/her property. Upon failure to remove any of the above items within the aforesaid period, they shall become the property of the U.S. Fish and Wildlife Service.

This application form is not valid as a permit but may be used as a reference document attached to the official permit. Only official refuge personnel may assign a valid permit number and permit term to this application form after the permit has been approved.

FWS Form 3-2469 12/2016

18-1083 LLOX Delta Duck Prospect SUP Attachment 1 03212019 1

Proposed Operations Start Date: May-July 2019 (pending regulatory approval)

Proposed Operations: Following approval, LLOX, LLC (LLOX) proposes to drill the Delta Duck Location “B” Prospects. The proposed well site is centered at approximate Latitude 29.233251° and Longitude -89.162505° in Section 4, Township 21 South, Range 20 East of Plaquemines Parish, Louisiana. Access to the location will utilize the Mississippi River at Main Pass to Octave Pass, thence to Buoy Pass into unnamed tributary and terminating at the well location in Dead Women Inside Pond. Approximately 3,642 cubic yards of water bottom will be displaced by propwashing at the well location for the drill barge to access the surface location of the proposed well. In addition to the proposed well location, LLOX is currently assessing the feasibility of several pipeline alternatives to link the proposed well to existing Texas Petroleum Investment Co. (TPIC) facilities. Upon selection of the preferred alternate, the pipeline will be installed via jetting within existing canals and bayous. Once drilled, the daily operations of the Delta Duck Location “B” Prospects will be performed by TPIC. The drilling operation is as follows: Facility Name: Delta Duck Location “B” Prospects Equipment:

• Coastal Drilling Company Drilling Barge, RIG 20 – 7’Draft • 2-Shale Barges • 2-Deck Barges • Tug Boat – 6’ Draft Duration: Approximately 42 days

The following procedure will be followed for the proposed Drilling Operation:

1. Using the field plat and known water depths, develop a route for the Drill Rig to navigate the waterways (Proposed Route is shown in attached plats). 2. Discuss navigation plan with Delta NWR representative for approval to proceed. 3. Give verbal notification to Delta NWR representative 24 hours prior to entering the refuge. 4. Mobilize equipment to location. 5. Perform operations on the Delta Duck Location “B” Prospects Well Location 6. Demobilize equipment out of the field when work is complete. 7. Inform the Delta NWR representative of any changes to equipment inventory in the field following operations.

LLOX, LLC Personnel Contact Information NAME TITLE OFFICE PHONE MOBILE Mike Kaberlein Drilling Manager 985-276-5700 504-495-7158 Marvin Van Allen Drilling Supervisor n/a 337-288-1600 Ron Harvey Operations Manager 985-276-5700 504-234-9275

18-1083 LLOX Delta Duck Prospect SUP Attachment 1 03212019 1

PART 3: Existing Conditions for Area of Operations

22) Describe the natural features including streams, lakes, ponds, wetlands, topographic relief, and areas the Service has indicated to you are sensitive.

The proposed work area is located in an “intermediate” marsh area, between the fresh marsh zone and the brackish marsh zone. The attached plats show the access route, well location and the pipeline alternatives in relation to the natural features.

23) Describe the locations of existing roads, trails, railroad tracks, pipeline rights-of-way, pads, and other disturbed areas. Please see attached plats.

24) Describe the locations of existing structures that your operations could affect, including buildings, pipelines, producing oil and gas wells, freshwater wells, underground and overhead electrical lines, and other utility lines. Please see attached plats.

25) Describe the natural resource and cultural resource survey reports for your proposed area of operations. Please see Appendix F and Appendix G of the Environmental Assessment for SHPO and USFWS concurrence. SHPO indicated there were no areas of concern and USFWS indicated that the area could provide habitat for the Endangered West Indian Manatee, the Bald Eagle and species of colonial water birds and migratory birds.

PART 4: PROPOSED NEW SURFACE USES

26) Describe and show the method and diagrams, including cross-sections, of any proposed pad construction, road construction, cut-and-fill areas, erosion control, and surface maintenance. Please see attached plats.

27) Describe the number and types of equipment and vehicles, including an estimate of vehicular round trips associated with each phase of operation. Please see attached plats.

28) Describe the estimated timetable for each phase of the proposed operations, including any operational timing constraints. Approximately _1_ day(s) for wheelwashing and drill rig mobilization

Approximately _20_ days for drilling the Delta Duck Prospect No. 001

Approximately _20_ days for drilling the Delta Duck Prospect No. 002

Approximately _1_ day to demobilize equipment/drill rig and move out of the Delta NWR.

18-1083 LLOX Delta Duck Prospect SUP Attachment 1 03212019 2

29) Describe the type and extent of security measures proposed at your area of operation. Drilling operations will be performed 24 hours a day. The drilling rig will be manned 24/7 and lighted at night. Associated vessels that are not manned 24/7 will be moored directly next to the drill rig and monitored by drill rig personnel 24/7.

30) Describe the power sources and their transmission systems for the proposed operations. The barges/tugs will be powered using onboard engines/generators. Please see Appendix C of the Environmental Assessment for the Coastal Drilling Company RIG-20 information sheet.

31) Describe the types and quantities of all solid and liquid waste generated and the proposed methods of storage, handling, and disposal. The barges will be equipped with their own individual sewage systems. The drilling fluids will be stored onsite in shale barges and disposed of properly offsite. Approximately 3,000 bbls of oil-based drilling fluids will be used, stored onsite in shale barges and returned to manufacturer for further processing upon drilling completion.

32) Describe the source, quantity, access route, and transportation/conveyance method for all water to be used in operations; and estimations of any anticipated waste water volumes generated and how they will be managed and disposed of. The drilling company will barge in freshwater to use in the drilling operation and will contain operational wastewater in barges that will haul the wastewater offsite to be disposed of properly. The routes to be used are indicated in the attached plats.

PART 6: DRILLING OPERATIONS

39) Describe the well pad construction, including dimensions and cross sections of: cut-and-fill areas and excavations for ditches, sumps, and spill control equipment or structures, including lined areas.

Please see attached plats.

40) Describe the drill rig and equipment layout, including rig components, fuel tanks, testing equipment, support facilities, storage areas, and all other well-site equipment and facilities.

Please see Appendix C of the Environmental Assessment for the Coastal Drilling Company RIG-20 information sheet.

41) Describe the type and characteristics of the proposed drilling mud systems.

An oil-based drilling mud is proposed. Please see Appendix C of the Environmental Assessment for the Coastal Drilling Company RIG-20 information sheet. The Material Safety Data Sheets are included as Attachment 2 with this SUP.

18-1083 LLOX Delta Duck Prospect SUP Attachment 1 03212019 3

42) List the equipment, materials, and methods of surface operations associated with your drilling, well casing and cementing, well control, well evaluation and testing, well completion, well stimulation, and well plugging programs.

Please see Appendix C of the Environmental Assessment for the Coastal Drilling Company RIG-20 information sheet.

PART 8: MITIGATION ACTIONS AND ALTERNATIVES CONSIDERED

49) Describe the steps you propose to take to mitigate anticipated adverse environmental impacts on refuge resources and uses, including but not limited to, the refuge’s land features, land uses, fish and wildlife, vegetation, soils, surface and subsurface water resources, air quality, noise, lightscapes, viewsheds, cultural resources, and economic environment.

Efforts will be made to avoid environmental impacts on refuge resources and uses. The USFWS concurrence of the proposed drilling operations indicates the area could be habitat for the West Indian Manatee, nesting habitat for the bald eagle, and nesting habitat for colonial and migratory water birds. The recommendations of the USFWS will be followed should these species be identified within the project area and LLOX will work closely with Delta NWR to minimize all impacts.

50) Describe any anticipated impacts that you cannot mitigate.

There are no anticipated impacts that cannot be mitigated.

51) List alternatives considered that met the criteria of technologically feasible, least damaging methods of operations, as well as the costs and environmental effects of those alternatives.

Alternatives are described in the Environmental Assessment. The preferred alternative, as proposed, requires less water bottom displacement (wheelwashing) and provides for open water access for pipeline placement and general navigation to and from the well location.

PART 9: SPILL CONTROL AND EMERGENCY PREPAREDNESS PLAN

59) Describe the notification procedures and steps taken to minimize damage in event of spill, fire, or accident. Please see Appendix D of the Environmental Assessment for the Coastal Drilling Co., LLC Spill Prevention Control and Countermeasure Plan (SPCC) for Coastal Rig 20, TPIC’s Emergency Response Plan (ERP), and TPIC’s SPCC.

60) Identify contaminating or toxic substances used within your area of operations or expected to be encountered during operations. Diesel fuel, drilling fluids, sewage and drilling wastewater are covered in the SPCC plan found in Appendix D of the Environmental Assessment and in SUP Attachment 2 MSDS sheets.

18-1083 LLOX Delta Duck Prospect SUP Attachment 1 03212019 4

61) Provide a trajectory analysis for potential spills not contained on location. N/A

62) Identify abnormal pressure, temperature, toxic gases or substances, or other hazardous conditions at your area of operations or expected to be encountered during operations.

Potential hazards and preventative measures are covered in the SPCCs.

63) Describe your measures (e.g., procedures, facility design, equipment, etc.) to minimize risks to human health, safety, and the environment.

Coastal Drilling Company, LLOX, and TPIC follow strict risk analysis and safety protocols to decrease the human health risks, as well as environmental risks. Please see Appendix D and Appendix E of the Environmental Assessment for SPCC plans and Emergency Response Plans.

64) Describe the steps to prevent accumulations of oil or other materials deemed to be fire hazards from occurring in the vicinity of well locations and lease tanks. Please see the SPCC for Coastal Rig 20 in Appendix D of the Environmental Assessment.

65) Describe the equipment and methods for containment and cleanup of contaminating substances, including a description of the equipment available at your area of operations and equipment available from local contractors. Please see the SPCC for Coastal Rig 20 in Appendix D of the Environmental Assessment.

66) Provide the storm water drainage plan and actions intended to mitigate stormwater runoff. The Coastal Rig 20 SPCC indicates that this rig has zero discharge and all runoff is contained and disposed properly offsite.

67) Provide the material safety data sheets for each material you will use/encounter during operations, including expected quantities maintained at your area of operations.

Please see Attachment 2 of this SUP.

68) Describe the emergency actions you will take in the event of injury or death to fish and wildlife or vegetation. Please see the SPCC for Coastal Rig 20 in Appendix D of the Environmental Assessment. Delta NWR and an outside consultant, Garner Environmental Service, will be notified.

69) Describe emergency actions you will take in the event of accidents causing human injury. 911 will be called and emergency first aid will be administered by trained personnel until emergency medical services have arrived or arranged for transportation of injured person.

70) Provide the contingency plans for conditions and emergencies other than spills, such as if your area of operations is located in areas prone to hurricanes, flooding, tornados, fires, or earthquakes. Please see the SPCC for Coastal Rig 20 in Appendix D of the Environmental Assessment.

18-1083 LLOX Delta Duck Prospect SUP Attachment 1 03212019 5

PART 10: RECLAMATION

71) List the specific equipment, materials, methods, and schedule used to meet the operating standards for reclamation

Reclamation of the well site will be completed with the appropriate LDEQ, Corp of Engineers and Office of Coastal Management permits, in accordance with the Office of Conservation 29B regulations.

72) Provide an itemized list of the estimated costs that a third party would charge to complete reclamation.

Reclamation of the well site will be completed with the appropriate LDEQ, Corp of Engineers and Office of Coastal Management permits, in accordance with the Office of Conservation 29B regulations.

18-1083 LLOX Delta Duck Prospect SUP Attachment 1 03212019 6

18-1083 LLOX Delta Duck Prospect SUP Attachment 1 03212019 7

PROJ No. 2016135_PL 10 miles 0 10 m i le s 20 miles I SCALE APPROXIMATELY 36 MILES SOUTHEAST OF PORT SULPHUR, LOUISIANA

LOC.

EQUIPMENT ROUTE

NOTE: WATER DEPTH VARIES 8' TO 12' ALONG ROUTE

LLOX, L.L.C. TWO PROPOSED 6" PIPELINES AND TWO PROPOSED 4" PIPELINES AND DELTA DUCK LOCATION "B" PROSPECTS LOCATED IN TOWNSHIPS 20 & 21 SOUTH - RANGE 20 EAST DELTA DUCK CLUB FIELD PLAQUEMINES PARISH, LOUISIANA SCALE: 1" = 10 MILES MARCH 15, 2019

APPLICATION BY EGR SERVICES, LLC A LLO X , L . L.C . 1330 PARK DRIVE, SUITE 300 1001 OCHSNER BLVD. , SUITE A MANDEVILLE, LA 70471 COVINGTON, LOUISIANA 70433 PH: (985)626- 7044 PH: (985) 276-5700 SHEET 1 STATE OF LOUISIANA FIRM No.: VF.0000762

PROJ. No. 2016135_PL 600 ' O ' 600' 1200' I SCALE

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= NAD) I X 2,692,396( 19 27 Y = 212,565 ALL COORDINATES AND BEARINGS ARE GRID, AND ARE ON THE LOUISIANA LAMBERT STATE PLANE LLOX, L.L.C. COORDINATE SYSTEM, SOUTH ZONE, 1983 NORTH AMERICAN DATUM. TWO PROPOSED 6" PIPELINES AND .l::IQIE;_ 1927 NORTH AMERICAN DATUM ALSO SHOWN. TWO PROPOSED 4" PIPELINES AND ALL COORDINATES ARE SHOWN IN U.S. SURVEY FEET. DELTA DUCK LOCATION "B" PROSPECTS .l::IQIE;_ EXISTING PIPELINES ARE NOT SHOWN. LOCATED IN 2017 USDA AERIAL PHOTO TOWNSHIPS 20 & 21 SOUTH - RANGE 20 DELTA DUCK CLUB FIELD EAST j PLAQUEMINES PARISH, LOUISIANA

SCALE: 1" = 600' MARCH 15, 2019

APPLICATION BY:

LLOX, L . L.C. EGR SERVICES, LLC 1001 OCHSNER BLVD, SUITE A 1330 PARK DRIVE SUITE 300 N COVINGTON, LOUISIANA 70433 MANDEVILLE, LA 70471 PH: (985) 276-5700 PH.: (985) 626-7044 SHEET 2 A STATE OF LOUISIANA FIRM No.: VF.0000762

PROJ No. 20 l6 /35 _P L 2000 ' o' 2000' 4000 ' I SCALE

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ALL COORDINATES AND BEARINGS ARE GRID, AND ARE ON THE LOUISIANA LAMBERT STATE PLANE LLOX, L. L. C. COORDINATE SYSTEM, SOUTH ZONE, 1983 NORTH AMERICAN DATUM. TWO PROPOSED 6" PIPELINES AND .t::IQIE;_ 1927 NORTH AMERICAN DATUM ALSO SHOWN. TWO PROPOSED 4" PIPELINES AND ALL COORDINATES ARE SHOWN IN U.S. SURVEY FEET. DELTA DUCK LOCATION "8" PROSPECTS LOCATED IN .t::IQIE;_ ADDITIONAL PIPELINES EXIST. TOWNSHIPS 20 & 21 SOUTH - RANGE 20 EAST 2017 USDA AERIAL PHOTO DELTA DUCK CLUB FIELD PLAQUEMINES PARISH, LOUISIANA SCALE 1" = 2000 ' MARCH 15 , 2019 1

APPLICATION BY:

LLOX , L.L . C. EGR SERVICES, LLC 1330 PARK DRIVE SUITE 300 N 1001 OCHSNER BLVD., SUITE A MANDEVILLE, LA 70471 COVINGTON, LOUISIANA 70433 PH.: (985) 626-7044 A PH: (985) 276- 5700 SHEET 3 STATE OF LOUISIANA FIRM No.: VF.0000762

PROJ No. 20 l6 /35 _P L

2000 ' o' 2000' 4000 '

I SCALE

_) SECTION 31 007 0 104 - J _L i 001 095 :::-i.--

/ SECTION 32 \ I T 20 S -R 20 E BUOY ---- - POND ◇ --- 014 ­ T 21 S -R 20 E

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s VD z '.¢0- 12 I 0 SECTION 9 (.) w V)

FLATBOAT PASS

ALL COORDINATES AND BEARINGS ARE GRID, AND ARE ON THE LOUISIANA LAMBERT STATE PLANE LLOX, L.L.C. COORDINATE SYSTEM, SOUTH ZONE, 1983 NORTH TWO PROPOSED 6" PIPELINES AND AMERICAN DATUM. .t::IQIE;_ 1927 NORTH AMERICAN DATUM ALSO SHOWN. TWO PROPOSED 4" PIPELINES AND ALL COORDINATES ARE SHOWN IN U.S. SURVEY FEET. DELTA DUCK LOCATION "B" PROSPECTS .t::IQIE;_ ADDITIONAL PIPELINES EXIST. TOWNSHIPS 20 & LOCATED IN 21 SOUTH - RANGE 20 EAST 2017 USDA AERIAL PHOTO DELTA DUCK CLUB FIELD PLAQUEMINES PARISH, LOUISIANA SCALE: 1 " = 2000' MARCH 15 , 2019 1

APPLICATION BY:

LLOX , L.L . C. EGR SERVICES, LLC 1330 PARK DRIVE SUITE 300 N 1001 OCHSNER BLVD, SUITE A MANDEVILLE, LA 70471 COVINGTON, LOUISIANA 70433 PH.: (985) 626-7044 A PH : (985) 276- 5700 SHEET 4 STATE OF LOUISIANA FIRM No.: VF.0000762

PROJ No. 2016135_PL

· Z 7' CENTERLINE OF PROPOSED

0 6 7' x 28' PROPOSED METAL WELL HEAD PROTECTOR r NAVIGA + (+) 5' (TYP) LIGHT - M.H.W. = +1.5' NA V.D. 88 -M.LW. - +0.0' NA V.D. 88 0 0 PILINGS EXISTING PROPOSED PLAN /x NO SCALE

ELEVATION TYPICAL METAL WELL HEAD PROTECTOR

NO SCALE

/ 3 PILE CLUST ERS

& & 00

TYPICAL DRILL BARGE I O

WELL LOCATION /

PLAN TYPICAL DRILL BA NO SCALE

WATER_LINE

'.-< o/ ; // '>Y'>Y/ / 1YPICAL DRILLING BARGE 198' x 54' ELEVATION TYPICAL DRILL BARGE NO SCALE LLOX, L.L.C. TWO PROPOSED 6" PIPELINES AND TWO PROPOSED 4" PIPELINES AND DELTA DUCK LOCATION "B" PROSPECTS LOCATED IN TOWNSHIPS 20 & 21 SOUTH - RANGE 20 EAST DELTA DUCK CLUB FIELD PLAQUEMINES PARISH, LOUISIANA NO SCALE MARCH 15, 2019

APPLICATION BY EGR SERVICES, LLC LLOX, L.L.C. 1330 PARK DRIVE, SUITE 300 1001 OCHSNER BLVD., SUITE A MANDEVILLE, LA 70471 COVINGTON, LOUISIANA 70433 PH: (985)626- 7044 PH (985) 276-5700 SHEET 5 STATE OF LOUISIANA FIRM No.: VF.0000762

PROJ No. 2016135_PL

±240' --

/

/ -- 160' --

SECTION "A-A" PROPOSED WHEEL WASHING IN EXISTING WELL SLIP NO SCALE

LLOX, L.L.C. TWO PROPOSED 6" PIPELINES AND TWO PROPOSED 4" PIPELINES AND DELTA DUCK LOCATION "B" PROSPECTS LOCATED IN TOWNSHIPS 20 & 21 SOUTH - RANGE 20 EAST DELTA DUCK CLUB FIELD PLAQUEMINES PARISH, LOUISIANA NO SCALE MARCH 15, 2019

APPLICATION BY

LLOX, L.L.C. EGR SERVICES, LLC 1001 OCHSNER BLVD., SUITE A 1330 PARK DRIVE, SUITE 300 COVING TON , LOUISIANA 70433 MANDEVILLE, LA 70471 PH: (985)626- 7044 PH (985) 276-5700 SHEET 6 STATt: OF LOUISIANA FIRM No.: VF.0000762

PROJ No. 2016135_PL

NOTES: TWO PROPOSED WELLS

1. Approximately 3,642 cubic yards of material will be displaced by wheel washing in existing well slip, impacting 1.5 acres of water bottoms.

2. All structures, facilities, well and pipelines/flowlines shall be removed within 120 days of abandonment of the facilities for the permitted use, unless prior written approval to leave such structures in place is received from the Coastal Management Division. This condition does not preclude the necessity for revising the current permit or obtaining a separate Coastal Use Permit , should one be required for such removal act ivities .

3. As-built drawings and/or plats shall have written on them the date of completion of said activities and shall be submitted to the Louisiana Department of Natural Resources, Office of Coastal Management, PO Box 44487, Baton Rouge, LA 70804-4487 within 30 days following project completion.

4. In order to ensure the safety of all parties, the permittee shall contact the Louisiana ONE CALL System (1-800-272-3020) a minimum of two (2) full business days prior to the commencement of any excavation (digging, dredging, jetting, etc .) or demolition activity.

5. All oil and gas platforms and appurtenant structures shall be marked/lighted in accordance with U.S. Coast Guard regulations.

6. These plans were prepared exclusively for obtaining regulatory permits. These plans are not engineering or construction drawings and should not be used as such.

7. This is not a Property Boundary Survey as defined in the "Standards of Practice for Boundary Surveys" per LAC Title 46:LXI §2907

LLOX, L.L.C. TWO PROPOSED 6" PIPELINES AND TWO PROPOSED 4" PIPELINES AND DELTA DUCK LOCATION "8" PROSPECTS LOCATED IN TOWNSHIPS 20 & 21 SOUTH - RANGE 20 EAST DELTA DUCK CLUB FIELD PLAQUEMINES PARISH, LOUISIANA NO SCALE MARCH 15, 2019

APPLICATION BY

EGR SERVICES , LLC LLOX, L.L.C. 1330 PARK DRIVE, SUITE 300 1001 OCHSNER BLVD., SUITE A MANDEVILLE, LA 70471 COVING TON , LOUISIANA 70433 PH: (985)626-7044 PH (985) 276-5700 SHEET 7 STATt: OF LOUISIANA FIRM No.: VF.00007 62

PROJ No. 2016135_PL

TWO PROPOSED 6" PIPELINES CENTERLINE OF _ PROPOSED 30' x 1O' PROPOSED PILE SUPPORTED LINE HEATER PLATFORM • ELEVATED WALKWAY

+5' ------

100' MINIMUM 17,500' OF JETTING IN EXISTING CANALS FOR INSTALLATION OF PIPELINES PROFILE CONTINUED BELOW >>> TYPICAL PIPELINE INSTALLATION ND SCALE

TWO PROPOSED 6" PIPELINES EXISTING FACILITY

/ / / /,

17,500' OF JETTING IN EXISTING CANALS FOR INSTALLATION OF PIPELINES CONTINUED FROM ABOVE >>> PROFILE TYPICAL PIPELINE INSTALLATION ND SCALE LLOX, L.L.C. TWO PROPOSED 6" PIPELINES AND TWO PROPOSED 4" PIPELINES AND DELTA DUCK LOCATION "B" PROSPECTS LOCATED IN TOWNSHIPS 20 & 21 SOUTH - RANGE 20 EAST DELTA DUCK CLUB FIELD PLAQUEMINES PARISH, LOUISIANA NO SCALE MARCH 15, 2019

APPLICATION BY

EGR SERVICES, LLC LLOX, L.L.C. 1330 PARK DRIVE, SUITE 300 1001 OCHSNER BLVD., SUITE A MANDEVILLE, LA 70471 COVING TON , LOUISIANA 70433 PH: (985)626- 7044 PH (985) 276-5700 SHEET 8 STATE OF LOUISIANA FIRM No,: VF,0000762

PROJ No. 2016135_PL

-- CENTERLINE OF WELL

TWO PROPOSED 4" PIPELINES

+5' ------

/ / / // / IN EXISTING CANALS FOR INSTALLATION OF PIPELINES CONTINUED BELOW >>>

PROFILE TYPICAL PIPELINE INSTALLATION PROPOSED 30' x 1O' ND SCALE LINE HEATER PLATFORM PROPOSED PILE SUPPORTED CENTERLINE OF WELLS:--- ELEVATED WALKWAY TWO PROPOSED 4" PIPELINES

■ ------· ------

8,313' OF JETTING IN EXISTING CANALS FOR INSTALLATION OF PIPELINES PROFILE CONTINUED FROM ABOVE >>> TYPICAL PIPELINE INSTALLATION ND SCALE LLOX, L.L.C. TWO PROPOSED 6" PIPELINES AND TWO PROPOSED 4" PIPELINES AND DELTA DUCK LOCATION "8" PROSPECTS LOCATED IN TOWNSHIPS 20 & 21 SOUTH - RANGE 20 EAST DELTA DUCK CLUB FIELD PLAQUEMINES PARISH, LOUISIANA NO SCALE MARCH 15, 2019

APPLICATION BY EGR SERVICES , LLC LLOX, L.L.C. 1330 PARK DRIVE, SUITE 300 1001 OCHSNER BLVD., SUITE A MANDEVILLE, LA 70471 COVING TON , LOUISIANA 70433 PH: (985)626- 7044 PH (985) 276-5700 SHEET 9 STATt: OF LOUISIANA FIRM No.: VF.0000762

PROJ No. 2016135_PL

TWO PROPOSED 6" PIPELINES TOTAL LENGTH = 17,630 L.F. LINE No. BEARING DISTANCE (in feet) 1 ss9•33'E 100' 2 so5•21'w 75' 3 N89.28'W 582' 4 N82.45'W 338' 5 N65.31'W 424' 6 N63• 15'W 1,027' 7 N63• 15'W 97' 8 N87° 31' W 595' 9 N72.21'W 1,004' 10 Nss· lO'W 331' 11 ss1· 15'W 476' 12 N81.49'W 944' 13 S83.29'W 414' 14 N53.52'W 732' 15 N22• 37' E 384' 16 Nos•5o'E 1,932' 17 Nl0•03'E 810' 18 N20.36'E 771' 19 S64.50'W 946' 20 sso•53'w 742' 21 SB6·oo'W 724' 22 ss9•33'w 3,802' 23 s10•23'E 276' 24 s19•37' w 104'

ID X NAD 27 Y NAD 27 ID X NAD 83 Y NAD 83 ID LAT 83 LONG 83 1 2692389 212565 1 3973192 273269 1 29• 14' 00'N 89.09'45'W 2 2692489 212564 2 3973292 273268 2 29• 14' 00'N 99•09'44'W 3 2692482 212490 3 3973285 273194 3 29• 13' 59'N 99•09'44'W 4 2691900 212495 4 3972703 273199 4 29• 14' 00'N 99•09' 51'W 5 2691565 212538 5 3972368 273242 5 29• 14' 00'N 89.09'55'W 6 2691179 212713 6 3971982 273417 6 29• 14' 02'N 89.09'59'W 7 2690262 213176 7 3971065 273880 7 29• 14' 07'N 99•10'09'W 8 2690176 213219 8 3970979 273923 8 29• 14' 07'N 99• 10' 10'W 9 2689581 213245 9 3970384 273949 9 29• 14' 07'N 99• 10' 17'W 10 2688624 213549 10 3969427 274253 10 29• 14' 11' N 99•10'28'W 11 2688293 213560 11 3969096 274264 11 29• 14' 11' N 99• 10' 31'W 12 2687823 213488 12 3968626 274192 12 29• 14' 10' N 99• 10' 37'W 13 2686888 213622 13 3967691 274326 13 29• 14' 12' N 89.10'47'W 14 2686477 213575 14 3967280 274279 14 29• 14' 11' N 99•10'52'W 15 2685886 214007 15 3966689 274711 15 29• 14' 16' N 99•10'58'W 16 2686034 214362 16 3966837 275066 16 29• 14' 19' N 99• 10' 57'W 17 2686330 216271 17 3967133 276975 17 29• 14' 38'N 99•10'53'W 18 2686472 217068 18 3967275 277772 18 29• 14' 46'N 99• 10' 51'W 19 2686743 217790 19 3967546 278494 19 29• 14' 53'N 99•10'48'W 20 2685887 217387 20 3966690 278091 20 29• 14' 49'N 99•10'58'W 21 2685154 217270 21 3965957 277974 21 29• 14' 48'N 99• 11' 06'W 22 2684432 217219 22 3965235 277923 22 29• 14' 48'N 99• 11' 14' W 23 2680630 217190 23 3961432 277894 23 29• 14' 48'N 99• 11' 57'W 24 2680680 216919 24 3961482 277623 24 29• 14' 45'N 99• 11' 56'W 25 2680577 216900 25 3961379 277604 25 29• 14' 45'N 99• 11' 58'W

LLOX, L.L.C. TWO PROPOSED 6" PIPELINES AND TWO PROPOSED 4" PIPELINES AND DELTA DUCK LOCATION "B" PROSPECTS LOCATED IN TOWNSHIPS 20 & 21 SOUTH - RANGE 20 EAST DELTA DUCK CLUB FIELD PLAQUEMINES PARISH, LOUISIANA NO SCALE MARCH 15, 2019

APPLICATION BY

EGR SERVICES, LLC LLOX, L.L.C. 1330 PARK DRIVE, SUITE 300 1001 OCHSNER BLVD., SUITE A MANDEVILLE, LA 70471 COVING TON , LOUISIANA 70433 PH: (985)626- 7044 PH (985) 276-5700 SHEET 10 STATE OF LOUISIANA FIRM No,: VF,0000762

PROJ No. 2016135_PL

TWO PROPOSED 4" PIPELINES TOTAL LENGTH = 8,443 L.F.

LINE No . BEARING DISTANCE (in feet) 1 s12°38'W 50' 2 S77°06'E 92' 3 N26°37'E 560' 4 N47° 49' E 1,491' 5 N48°46'E 1,004' 6 N38°28'E 435' 7 N06°49'E 334' 8 N07° 49' E 461' 9 N10°09'E 334' 10 N28°46'E 468' 11 N38°58'E 267' 12 N47°21'E 402' 13 S63°15'E 1,027' 14 S65°31'E 424' 15 S82°45'E 337' 16 S89°28'E 582' 17 N05°21'E 75' 18 N89°33'W 100'

ID X NAO 27 Y NAO 27 ID X NAO 83 Y NAO 83 ID LAT 83 LONG 83 1 2686952 208733 1 3967755 269437 1 29°13'23'N 89°10'47'W 2 2686942 208685 2 3967745 269389 2 29°13'23'N 89°10'48'W 3 2687032 208664 3 3967835 269368 3 29°13'23'N 89°10'47'W 4 2687283 209165 4 3968086 269869 4 29°13'27'N 89°10'44'W 5 2688387 210166 5 3969190 270870 5 29°13'37'N 89° 10' 31•w 6 2689142 210828 6 3969945 271532 6 29°13'44'N 89°10'22·w 7 2689413 211168 7 3970216 271872 7 29°13'47'N 89° 10' 19• w 8 2689452 211499 8 3970255 272203 8 29°13'50'N 89° 10' 19• w 9 2689515 211956 9 3970318 272660 9 29°13'55'N 89° 10' 18' w 10 2689574 212285 10 3970377 272989 10 29°13'58'N 89° 10' 17• w 11 2689799 212696 11 3970602 273400 11 29°14'02'N 89° 10' 14• w 12 2689967 212903 12 3970770 273607 12 29°14'04'N 89° 10' 12· w 13 2690262 213176 13 3971065 273880 13 29°14'07'N 89°10'09'W 14 2691179 212713 14 3971982 273417 14 29°14'02'N 89°09'59'W 15 2691565 212538 15 3972368 273242 15 29°14'00'N 89°09'55'W 16 2691900 212495 16 3972703 273199 16 29°14'00'N 89°09'51'W 17 2692482 212490 17 3973285 273194 17 29°13'59'N 89°09'44'W 18 2692489 212564 18 3973292 273268 18 29°14'00'N 89°09'44'W 19 2692389 212565 19 3973192 273269 19 29°14'00'N 89°09' 45'W

LLOX, L.L.C. TWO PROPOSED 6" PIPELINES AND TWO PROPOSED 4" PIPELINES AND DELTA DUCK LOCATION "8" PROSPECTS LOCATED IN TOWNSHIPS 20 & 21 SOUTH - RANGE 20 EAST DELTA DUCK CLUB FIELD PLAQUEMINES PARISH, LOUISIANA NO SCALE MARCH 15, 2019

APPLICATION BY

LLOX, L.L.C. EGR SERVICES, LLC 1001 OCHSNER BLVD., SUITE A 1330 PARK DRIVE, SUITE 300 COVING TON , LOUISIANA 70433 MANDEVILLE, LA 70471 PH (985) 276-5700 PH: (985)626-7044 SHEET 11 STATE OF LOUISIANA FIRM No,: VF,0000762

PROJ No. 2016135_PL

1 2' er-

PROPOSED JETTING FOR 7 ACCESS TO PIPELINE _ ,,,.,,---EXISTING / PIPELINE

r

X 0 PROPOSED - Q'. "'o.. PIPELINES Q_ <{

N

X 0 - Q'. n o_ j _I T

PLAN

PIPELINE CROSSING

NO SCALE - z tj- - 2 EXISTING PIPELINE MUDLINE

PROPOSED

1 ON 3 PIPELINES SLOPE

, d 'ro -::,; NOTES:

1 . SAND BAGS SHALL BE USED AT PIPELINE CROSS INGS. 2. AFTER FILLING, BAGS WILL BE CLOSED BY SEWING OR THE EQUIVALENT. ELEVATION 3. . BAGS SHALL BE MADE OF PIPELINE CROSSING CLOSELY WOVEN MATERIAL WITH A WICKING ACT ION . NO SCALE 4. APPROXIMATELY 5 CUBIC YARDS OF SANDBAGS WILL BE INSTALLED FOR EACH CROSS ING. LLOX, L.L.C. TWO PROPOSED 6" PIPELINES AND TWO PROPOSED 4" PIPELINES AND DELTA DUCK LOCATION "8" PROSPECTS LOCATED IN TOWNSHIPS 20 & 21 SOUTH - RANGE 20 EAST DELTA DUCK CLUB FIELD PLAQUEMINES PARISH, LOUISIANA NO SCALE MARCH 15, 2019

APPLICATION BY:

EGR SERVICES, LLC LLOX , L.L.C. 1330 PARK DRIVE, SUITE 300 1001 OCHSNER BLVD., SUITE A MANDEVILLE, LA 70471 COVINGTON, LOUISIANA 70433 PH: (985)626- 7044 PH (985) 276-5700 SHEET 1 2 STATt: OF LOUISIANA FIRM No.: VF.0000762

M ATRI XN EW O RL D Engineering Progress

ATTACHMENT 2 MATERIAL SAFETY DATA SHEETS FOR DRILLING OPERATIONS SPECIAL USE PERMIT FOR LLOX, LLC DELTA DUCK PROSPECT IN DELTA NWR, PLAQUEMINES PARISH, LOUISIANA

ATTACHMENT INTENTIONALLY OMITTED

COASTAL DRILLING COMPANY 311 Saratoga Blvd. 5319 Port Road Corpus Christi, Texas 78417 New Iberia, Louisiana 70560 Ofc: 361-852-6195 Ofc: 337-560-4446

RIG-20 INVENTORY CDC RIG #20: 24 hour inland barge drilling rig rated to 16,000 feet nominal with 5” drill pipe. Remedial operations to 20,000 feet.

Barge Information: • Dimensions: Length 195 feet, Width 54 feet, Depth 12 feet Draft 7 feet • Well Slot: Length 50 feet, Width 10 feet, Centerline well to forward well slot bulkhead 10 feet • 3-36 foot positioning spuds

Drawworks: National 110M, 6032 Baylor Electric Brake , National B-1 catheads, 6 hoisting speeds. (2280 input horsepower) National 3 engine compound with Quincey 5120 air compressor.

Top Drive: Varco TDS-11 Electric 500 Ton Unit

Drawworks Power: 3-D-398 DITA diesel engines rated at 760HP each with National C-300-64-FH torque convertors.

Mast: Dreco Division; National Oilwell Co., Angle Leg, 142 foot height x 25 feet base spread, 760,000 lb. static hook load strung on 12 lines with 1 3/8” drill line. Dual standpipes, middle board.

Substructure: Fabricated inland barge type 30” diameter pipe legs rated at 1,500,000 lb. capacity.

Hoisting/Traveling Equipment: National/650G500 hook/block 500-ton capacity, National P-500, Varco pin drive bushing

Rotary: National/C275, 27 ½” maximum opening, split bushing, pin drive, 500-ton rated capacity, drawworks driven.

Air Slips: Back Saver air operated slips. Slips are offset and compatible for a Top Drive

Rotating Mouse Hole: Access- Phantom Mouse Speed 0-65 RPM. Stall Torque 1,500 LBS

Mud Pumps: 2-Gardner-Denver Model PZ-11 triplex pumps powered by Caterpillar 3516 DITA diesel engines rated at 1649HP with National C-300-125-FH torque convertors. 11” stroke, 115 maximum rpm.

Mud System: 1000bbl total capacity with dividers, equalizers, guns, mixing/treating manifold and hopper system.

Solids Control Equipment: 1- Brandt Gumbo Removal Box, 2- Brandt dual “King Cobra” Shakers, 1 - “Cobra” 16-2 mud conditioner, 1-DG-10 drilling mud degasser, Brandt MA-10 and MA-15 mud agitators.

Bulk Barite Storage: (2) 1000 sack capacity with rotary screw compressor and dryer system.

Electrical Power: 3-600KW Caterpillar SR4B generators powered by D-3412 DITA Caterpillar engines. 1- 210KW Caterpillar SR4 standby generator powered by Caterpillar D-3306 diesel engine. General Electric Motor Control Center and Main Generator Control Switchboard set for parallel operation and built to US Coast Guard specifications.

Blowout Prevention and Well Control Equipment: 1-13 5/8” 5M GK Hydril ; 1-13 5/8” 10M Cameron Type U double ram BOP, 1-13 5/8” 10M Cameron Type U single ram BOP, dressed with 5” pipe rams and shear ram 2-3 1/16” kill line valves 10M ; 2- 3 1/16 HCR valves 10M ; 3 1/16 choke manifold with Cameron H2S trim ; 2-3 1/16” 10M adjustable chokes ; 1-10M swaco choke and control ( swaco choke and control will be charged to the operator) ; gas buster ; massco model 160AM6A2 accumulator with 6-stations, 2-SD-1 air PI air pump and electric triplex pump.

Measuring Line: Mathey “Surveyor” 20,000 foot .092-diameter wire with standard MD Totco 8 degree mechanical drift indicator.

Air Compressors : 2 –Sullivan 60 HP screw drive with dry air system

Cranes: Main crane; Applied Hydraulics 60 foot fixed boom 30-ton capacity. Grocery crane; EBI hydraulic 40 foot fixed boom 5-ton capacity.

Fluid Capacities: 1. Main Fuel compartment - 39,737 gallons 2. Auxiliary fuel bunkers (day tanks) – 4000 gallons 3. Drill Water – 98,024 gallons 4. Potable Water – 40,184 gallons 5. Brake Water – 20,000 gallons 6. Pollution compartment – 20,000 gallons

RIG HAS ZERO-DISCHARGE CAPABILITIES

Instrumentation: PETRON Equipment: EDR System (Provided by Contractor). Optional equipment installed on rig for additional operator charges.

Drill String: 14,500’ 5” 19.50lb. S-135 drill pipe, 30 jts. 5” HWDP, 10-8” spiral drill collars, 15 – 6.50 jts.spiral drill collars. Crossovers, saver subs, bit subs and handling subs. All drill string handling tools.

Auxiliary Pumps: Drill water, bay water, washdown, mud mixing, solids control pumps, charging pumps, 10” Marlow de-ballasting pump. Fuel transfer pumps.

Quarters/Office: Air-conditioned accommodations for 36 persons. Full kitchen and galley. Private offices and state rooms for rig supervisor and operator’s representative. Separate laundry facilities and crew change room. Satellite TV.

Marine Sanitation Device: Owens Kleentank USCG, Type II MSD – 1125GPD hydraulic loading for black water treatment only.

Miscellaneous Equipment: 5 Ingersoll Rand varying capacity air hoists for materials handling. Electric welding machine, cutting burning rig, “Spinner Hawk” J-29 pipe spinner, marine radio/telephone, cellular telephone, telefax.

Marine Equipment: One crew boat with skipper. One deck barge for contractor’s drill string.

SPILL PREVENTION CONTROL & COUNTERMEASURE PLAN

Coastal Rig 20

SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN

(SPCC)

Coastal Drilling Company, L.L.C.

Rig 20

SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN (SPCC PLAN)

I. Introduction

Coastal Drilling Company, L.L.C., (CDC) operates a Mobile Inland Barge Drilling Unit rig for drilling, completion and/or workover of hydrocarbon producing zones in coastal zones of the Gulf of Mexico. This rig was constructed in 2002.

This Spill Prevention Control and Countermeasure Plan (SPCC) has been prepared to satisfy the requirements of the United States Environmental Protection Agency (EPA) as stated in Title 40, Code of Federal Regulations, Part 112.7 (40 CFR 112.7).

The objective of this SPCC plan is to prevent the discharge of oil or other substances in harmful quantities in to the navigable waters of the United States or adjoining shorelines, and to minimize the effects of a discharge should one occur. This objective will be accomplished by making certain that:

A. Coastal Drilling Company, L.L.C. employees and contractors are trained to minimize human errors that cause spills.

B. Coastal Drilling Company, L.L.C. personnel are trained to report any spill or sheen on waterways they may encounter, whether from Coastal Drilling Company, L.L.C. facilities or from unknown sources.

C. Adequate inspection procedures are implemented .

D. Pollution prevention equipment installed at the facility is in good working order and adequately maintained.

E. Adequate provisions have been made to contain and remove any oil that may be discharged into nearby waterways. These provisions include training of Coastal Drilling Company, L.L.C. personnel in cleanup and containment and through agreements with oil spill cleanup organizations.

In the event of a discharge from CDC operated facilities, it will be the responsibility of Coastal Drilling Company, L.L.C. to contain and remove the spill. The Management of Coastal Drilling Company, L.L.C. will certify their approval and will implement this plan. (See Appendix A)

II. Regulatory Specifics

Title 40, Code of Federal Regulations, Part 112 (40 CFR 112), establishes procedures, methods and equipment, and other requirements to prevent the discharge of oil into or upon the navigable waters of the United States or adjoining shorelines.

Part 112.7 (c) states the minimum requirements for containment, stating in part:

(c) Appropriate containment and/or diversionary structures or equipment to prevent discharged oil from reaching a navigable waterway should be provided. One of the following preventative systems or its equivalent should be used as a minimum:

1) Onshore ... 2) Offshore facilities ...

i. Curbing or drip pans ii. Sumps and collection systems

Additional sections under 40 CFR 112.7 address inspections, reports, security and training. This plan conforms to the requirements set forth in Part 112.

Title 40, CFR 117.11 applies to discharges of quantities of designated substances equal to or greater than the reportable quantities when discharged in the United States whether on water or soil unless in compliance with permits, approved operations, or in compliance with instructions from the Federal On-Scene Coordinator (FOSC). Designated substances include oil, oil field chemicals, acid, poisons, etc.

States located along the Gulf of Mexico also require SPCC Plans. These states require reporting all oil chemical discharges whether to water, soil, or air in excess of reportable quantities.

Failure of any person to report a spill of a reportable quantity to the appropriate agency of the United States Government is punishable, upon conviction, to a fine of not more than $10,000 or to imprisonment of not more than one year, or both.

Any person who is the owner, operator or person in charge of a facility from which oil or a hazardous substance is discharged may be subject to a civil penalty in an amount up to $25,000 per day of violation or an amount up to $1,000 per barrel of oil or unit of reportable quantity (RQ) of hazardous substances discharge d.

It is the policy of Coastal Drilling Company, L.L.C. that all spills be reported to the Oil Spill Response Coordinator for determination if a spill is reportable to the Federal and/or State agencies.

Ill. Definitions

Oil means oil of any kind or in any form, including, but not limited to; petroleum, fuel oil, sludge, oil refuse and oil mixed with wastes other than dredge spoil.

Discharge includes, but is not limited to, any spilling, leaking, pumping, emitting, emptying, or dumping. This does not include substances discharged that are authorized by a permit.

Navigable waters includes all waters that are currently used, were used in the past, or may be susceptible to the use in interstate or foreign commerce, including all water subject to the ebb and flow of the tide, interstate waters, wetlands, and their tributaries; interstate lakes, rivers, streams (including intermittent streams), mudflats, sandflats, wetlands and their tributaries.

Harmful quantities means any discharge of oil or hazardous substances into or upon the waters of the United States that may be harmful to the public health or welfare including discharges that may cause a film or sheen upon or discoloration of the surface of the water or adjoining shorelines or cause a sludge or emulsion to be deposited beneath the surface of the water or upon the adjoining shorelines.

Sheen means an iridescent appearance on the surface of the water.

Sludge means an aggregate of oil or oil plus other matter of any kind in any form other than dredged spoil having a combined specific gravity equivalent to or greater than water.

Spill Event means a discharge of any reportable quantity of any substance emitted into the air, water or land of the United States.

Reportable Quantity (RQ} means the quantity of a hazardous substance that triggers a response under Federal or State guidelines.

Remove or Removal refers to the removal of the oil from the water and shorelines or the taking of such action as may be necessary to minimize or mitigate damage to the public health or welfare, including, but not limited to fish, shellfish, wildlife, and public and private property, shorelines, and beaches.

Oil Spill Removal Organization means a company or organization that responds to and removes oil or chemical spills. (Example: Garner Environmental, ICI, AMPOL)

Federal On-Scene Coordinator (FOSC) refers to the pre-designated EPA or Coastal Guard official whom coordinates and directs removal actions. The FOSC is the person-in-charge at any spill cleanup site.

SPILL PREVENTION CONTROL & COUNTERMEASURE PLAN

Name of Facility: Rig# 20

Type of Facility: Mobile Inland Barge Drilling Unit

Location of Facility: Protected Inland Waters of Louisiana and Texas

Name and Address of Owner or Operator: Name: Coastal Drilling Company, L.L.C. Address: 5319 Port Road New Iberia, LA 70560

' Designated Person Accountable for Oil Spill Prevention at Facility:

Name: JR Lofton Title: Rig Superintendent

MANAGEMENT APPROVAL

This SPCC Plan will be implemente ein described:

Name: J. Chris McClanahan

Title: Managing Partner

CERTIFICATION

I hereby certify that this SPCC Plan has been prepared with good engineering practices and fulfills the requirements of 40 CF_,_.. 112.

> . '

..... " ..

V. Emergency Telephone Numbers

• Federal Agencies

National Response Center (800) 424-8802 NRC Duty Officer Washington, D.C. 20593

U.S. EPA, Region VI (866) 372-7745 Regional Oil Spill Response Center (800) 887-6063 Emergency Response Branch 1445 Ross Avenue

Dallas, Texas 75202-6475

• State Agencies

Texas General Land Office (800) 998-4456 Austin, Texas (512) 463-5001

Texas Railroad Commission (713) 869-5001 Oil & Gas Division, District 3 Houston, Texas

TCEQ (800) 832-8224 (Texas Commission of Environmental Quality)

Louisiana

Louisiana State Police (225) 925-6595 Hazardous Material Hot Line (877) 925-6595 Baton Rouge, Louisiana

Louisiana Department of Environmental Quality (225) 342-1234 Baton Rouge, Louisiana

VI. Description of the Drilling Rig

The Drilling Rig operated by Coastal Drilling Company, L.L.C. is designed on a barge 198' 5" long by 54' 3" wide. The barge drafts six (6) feet and has a total of 11'8" from bottom to top of barge. Located within the barge's hull are six (6) tanks including a 37,056-gallon fuel tank, an 27,643-gallon potable water tank, a 97,399-gallon drill water tank, a 17,000- gallon brake water tank, a 14,000 keyway anti-pollution tank, two 21,000-gallon (500-barrel) anti-pollution tanks. The remaining hull (785,000 gallons/18,700 barrels) is for ballast water.

VII. Containment and Drainage

The storage tanks containing fuel oil, potable water, drilling water, anti-pollution tanks and produced water are contained within the hull of the rig. All areas where chemicals, dry drilling products, mixing tanks, shakers, etc. are stored and used are protected by a minimum 4" steel coaming. Collection drains are located throughout the flooring to collect any spills that may occur in the work area, the loading area and top deck. The collection drains are attached to anti-pollution tanks. Excess rainwater will be drained to the collection system and transferred to the anti-pollution sumps in the beam of the barge. A skimming tray is installed in the door of the keyway to capture any spillage in the keyway and to direct such spillage to the keyway anti-pollution tank. Some machines have separate coamings that are cleaned on a regular basis. (See Drawings -Appendix B)

VIII. Impracticality

CDC's Mobile Inland Barge Rig has secondary containment; however a large volume or high velocity spill could escape from the confines of the vessel. Due to areas where this vessel expects to operate, a spill that escaped from the facility's secondary containment area could potentially enter a waterway. Therefore, a spill response plan is enclosed.

IX. Prediction of Discharge Areas and Direction

Source Major Type Quantity Rat e Direction Secondary of Failure BBL BBL/ hr. of Flow Containment

Diesel Storage Rupture 882 860 Circular Hull of Barge Tanks Leak 882 25 Circular Hull of Barge

Drill Water Rupture 2319 335 Circular Hull of Barge Tank Leak 2319 25 Circular Hull of Barge

Brake Water Rupture 405 335 Circular Hull of Barge Tank Leak 405 5 Circular Hull of Barge

Anti-Pollution Rupture 500 each 500 Circular Hull of Barge Tanks (2) Leak 500 each 5 Circular Hull of Barge

Discussion :

Storage tanks for fuel, drill water, brake water, keyway anti-pollution and two (2) barge anti-pollutions are contained within the hull of the barge.

A 10" drainpipe carries to the anti-pollution tanks all spilled fluids from gutters located on all decks where oil or other chemicals may spill. Drain lines from the upper decks are monitored from the lower decks. Leaks can be easily noticed and repairs can be affected immediately.

All machinery is located in areas where leaks will be trapped by coaming. Some equipment is located within independent coaming or drip pans, which are monitored and cleaned on a regular basis. Residual oil or other chemicals spilled on decks or in coaming areas will be cleaned using the on-board spill kit and disposed of properly. The fuel day tanks are contained with coaming with drains that connect with the main anti -pollution tan ks. The keyway skimmer will skim oil or other contaminant spills falling in the keyway area. The skimmer contents are pumped into the keyway anti-pollution tank. Fluids entering the main anti-pollution tanks can be monitored and discharged either into the keyway for further monitoring or discharged to a barge for disposal at a shorebase or other approved facility.

X. Personnel Training

Coastal Drilling Company, L.L.C. has qualified personnel to operate the rig. All personnel are trained on the contents of the SPCC.

All personnel are trained to look for and report any spill that may be caused by oil without regard as to the origin of the spill. Personnel are also trained to look for leaks on fittings, wellheads, and equipment as they work in the various areas. Rig personnel will immediately begin repairs or other remedies to stop the spill.

Contractors working on the rig performing work on the well receive a safety orientation that discusses the separate and joint operations of the work to be performed. This orientation discusses what to do in an emergency, required pollution prevention equipment, alarms, notification procedures, etc. Written procedures are provided and placed on bulletin boards or other prominent locations accessible to all employees, contract or otherwise.

XI. Spill Prevention Procedures

Drain lines are constructed of schedule 40 pipe or better and are placed so as to be protected from damage during normal operations. Piping for equipment used to work on the well is schedule 120 or better. Pressure tests at design pressures are made during construction and after modifications, as required. Storage containers are compatible with the materials stored within said containers.

Equipment designed to contain spills during maintenance is used to collect any fluids that may leak from the equipment being worked on. Spill control equipment includes pans, buckets, and oil sorbent pads. Additional equipment as needed will be provided as necessary to prevent spills. (See Appendix C)

The Rig Superintendent is responsible for daily checks of the perimeter of the rig, inspection of the collection systems, drip pans, keyway area, etc. and arranges for cleanout whenever necessary.

Well Head Control

Drilling of new wells requires the use of a BOP on the drilling rig to prevent leaks of gas or oil, which has the potential to pose substantial risks to the crew and rig. Coastal Drilling Company, L.L.C. requires drilling rig personnel, particularly drillers and toolpushers attend and pass classes in blowout prevention and control.

Well workover requires the use of a two stage BOP. This BOP is designed to seal around tubing as required through the use of the upper stage while the lower stage of the BOP is used to seal the well if the tubing is removed.

The work being performed determines the type of BOP required.

Pollution Prevention Equipment

Description Inspection Procedures Test Procedures

Coamings Visual for Corrosion Daily

Drain Lines Checked Daily for Visual Inspection Signs of Leaks

Blow Out Preventer Checked for Signs of Leaks Visual Inspection

Test to 10,000 # psi Weekly

Well Control Systems and Equipment

Item Description Method of Activation Blow Out Preventer Twin Ram, High Pressure Air over hydraulic, Located on the Well manually activated from drill floor

Test to 5,000 # psi Weekly Mud Pumps 2 -Gardner Denver PZ-11 Triplex Pumps run during operations on pumps powered by Caterpillar the well. Only one may run 3516 DITA engines depending on operations and during maintenance.

Mud System 1000 BBL Tank Directly connected to Mud Pumps

XII. Security

Security on the rig consists of twenty-four (24) hour operations. The rig is constantly manned and the rig and area is well lit. Boats or other traffic can be seen by personnel on the rig before arrival.

XIII. Inspection and Testing

Personnel assigned to the rig are familiar with this SPCC plan and are trained in the operation of the equipment located throughout the facility. They are responsible for the operation and visual inspection of the facility and operating equipment. Any leaks or malfunctions are reported and repaired or replaced promptly . (See Appendix D)

The inspections or checks of the equipment and facility operations will include:

Daily:

Evidence of spills or leaks

Check wellhead equipment for leaks

Annually:

Review this SPCC Plan for additions or changes

XIV. Coastal Drilling Company, L.L.C. Spill Control and Cleanup Equipment

Coastal Drilling Company, L.L.C. maintains equipment to contain and control a spill on the rig. This equipment includes absorbent booms, absorbent pads, and boom material. Spill control and clean-up equipment is stored throughout the facility in areas where spills may occur. A spill kit is located on the rig where the risk of spill is highest. The contents of the spill kit are only to be used during an actual event. Other materials described above are kept separate and replaced as necessary.

Additional manpower is available from Garner Environmental Services and Industrial Cleanup Incorporated (ICI). These companies have considerable experience in cleanup equipment and techniques and are available on a 24-hour basis.

Coastal Drilling Company, L.L.C. will respond with the appropriate manpower and equipment if an oil spill occurs. Personnel will shut in the well and/or rig and take all steps necessary to stop the leak at the source. All efforts will then be made to contain the spill on the location and begin cleanup both at the source and ahead of the spill to minimize the spill damage.

Instruction to Contractors:

1) Discharge no oil.

2) Do not operate valves or pumps without the approval of company representatives.

3) Check that all fluids are removed from lines before disconnecting lines that may discharge to the surrounding areas.

4) Do not make or break connections without the approval of company representatives or personnel.

Garner Environmental Service 19701Chef Menteure Hwy. New Orleans, Louisiana 70129 {504) 254-2444 Or t h 1717 W. 13 Street Deer Park, Texas 77536 (800) 824-1716

lndustria./ Cleanup Incorporated (IC/) 129 ICI Lane P.O. Box 866 Garyville, Louisiana 70051 {800) 436-0883

APPENDIX A

Certification

IV. Owner and Operator

The operator of the facility is:

Coastal Drilling Company, L.L.C. 311 Saratoga Blvd. Corpus Christi, Texas 78417-3506 4 Atrention: Mr. J. Chris McClanahan cfl f,t, Jl. .J Managing Partner Signature

Telephone: (361) 852-6195 Facsimile: (361) 852-6676

The Oil Spill Response Coordinator for Coastal Drilling Company, L.L.C. is:

Coastal Drilling Company, L.L.C, 5319 Port Road New Iberia, LA 70560

Attention: Mr. Robert Boudreaux HSEManager

Attention: Mr. Floyd Lofton Jr. Drilling Superintendent

Telephone (337) 560-4446 Facsimile: (337) 560-4469

The designated person responsible for oil spill prevention & reporting at the rig will be the Rig Toolpusher.

This facility is a Mobile Inland Barge Workover/Drilling Rig. Latitude and Longitude measurements will be posted in the control room and offices on board for response uses. The rig will operate in shallow water areas in accessible depth ranging from 8' to 22' water.

APPENDIX B

Drawings

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APPENDIX C

Contents of Spill Kit

CONTENTS OF SPILL KIT

Personal Protective Equipment:

A. 5 Disposable Respirators B. 5 Tyvek Chemical Suits c. 5 Pairs Nitrile Gloves D. 5 Pairs Chemical Goggles E. 5 Full Faced Shields (Hard Hat Attachable)

Containment Equipment:

A. 2 PVC Scoop Shovels (Square Point) B. 2 - 55 Gallon Plastic Overpack Drums C. 1 Hand Wringer D. 16 Absorbent Booms (5" X 10') E. 220 Absorbent Pads (18" X 18") F. 3 Oil Mops with Handles G. 5 Oil Mop Heads H. 1 Case Visco-Sweep-Pam-Porns I. 2 Bags (40 lbs.) Cell-u-Sorb or 40 lbs. Sphag-Sorb

Transfer Equipment:

A. 1 Air powered fluid transfer pump with hoses and skimmers

APPENDIX D

Weekly Pollution Prevention Checklist

WEEKLY POLLUTION PREVENTION CHECKLIST

Actions Yes No Comments 1. Drip pans are inspected and cleaned daily and all drains are directed into sump tank or keyway cellar area. 2. Sump tank emptied and oil in keyway skimmed off or removed regularly.

3. Keyway sump pump working properly.

4. Floating oil containment boom outside keyway gate in place, secured and in good condition. 5. Spill Kit inventory complete.

6. Visual inspection conducted of waters around barge for sheen on water.

7. Pollution gates installed and in good condition. Rubber seals intact.

8. Keyway spray system operating properly.

9. Seawall coamings in good condition .

10. Pit level indicators in proper working condition. 11. Are all valves, lines and tanks free of excessive corrosion? 12. Have all waste oil or oily mat erials been removed and transported to shore for proper disposal? 13. Have all visitors to the rig been given a review of the SPCC Plan and understood their responsibilities under the plan? 14. Have you conducted a review of the SPCC Plan with employees? 15. Have any spills occurred and have they been reported to the operator's representatives and the appropriate authorities?

Additional Comments:

Rig Superintendent Signat ure :

Texas Petroleum Investment Company

DELTA DUCK FIELD

EMERGENCY RESPONSE PLAN

Delta Duck Field Emergency Response Plan

REVIEW AND REVISION SHEET

This Emergency Response Plan should be reviewed annually. The person conducting review should sign their initials and put the date of the review.

If there are any revisions or additions, whoever puts them into the Emergency Response Plan must also sign their initials and put the date the revision or addition was incorporated into the Emergency Response Plan.

INITIALS DATE

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Delta Duck Field Emergency Response Plan

Table of Contents

1.0 Introduction

1.1 Scope 1.2 When to Implement

2.0 Specific Incidents

2.1 Fire/Explosion 2.2 Medical 2.3 Natural Disasters 2.4 Spills 2.5 Gas/Toxic Releases

3.0 Responsibilities

4.0 Notification Requirements

5.0 Incident Command System

6.0 Legal

7.0 Public Affairs (Media)

8.0 Training and Drills

9.0 Emergency Telephone List

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1.0 INTRODUCTION

This plan will serve as a guide to help those people either directly or indirectly involved in an emergency situation should one arise within the Delta Duck producing area of Texas Petroleum Investment Company. The Delta Duck procedures include the Delta Duck production fields. Its purpose is to assign responsibilities to the designated people and serve as a guide to direct attention to areas where needed.

It is recognized that this written manual alone will not provide the assurance of proper handling of response actions during emergencies. However, if used properly in conjunction with emergency response training and sound judgment, it will lessen the impact of emergency response actions on human life, the environment and property.

This plan will help the employees of Texas Petroleum Investment Company and anyone responding to a given emergency at any of the facilities. It will attempt to address several emergency scenarios. As a matter of practicality, however, there are some emergencies that will not be addressed by the plan.

This plan will be reviewed annually to ensure the best possible response to emergency situations in the community.

1.1 Scope

This emergency response plan contains specific emergency response action to incidents that may occur in the Delta Duck field. The plan addresses emergency response for the following incidents within the geographic area:

Fire/Explosion Gas/Toxic Gas Release Personnel Injury or Fatalities Natural Disasters Spills

1.2 When to Implement the Plan

This emergency response plan shall be implemented when any of the following occurs:

- When injures or a fatality occurs, either company or contract. - Fire/explosion results in damage to non-TPIC property or facilities or outside assistance is required to control the incident. - Spill or release which migrates from TPIC property. - TPIC or public attention has been aroused. - Community authorities and agencies have become involved.

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2.0 SPECIFIC INCIDENTS

2.1 Fires and Explosions

- Evacuate area of non-essential personnel. Account for all persons.

- Evaluate situation.

- Notify others of the emergency. Call the foreman and your office or other TPIC employees, and state the nature of the situation.

- If needed, request notification of emergency response groups such as Coast Guard.

- Shut off the fuel source and ignition sources (open flames, heaters, electric power) before attempting to extinguish the fire. Never extinguish flammable gas fires until the gas supply has been shut off.

- Never jeopardize personal safety when fighting fires.

- Only attempt to extinguish fires that are small and can be extinguished rapidly with available equipment.

- Do not allow by-standers to stay on site.

- TPIC personnel should remain on nearby to give directions to the fire and provide technical assistance to the Coast Guard.

- Foreman should notify the Manager and Safety/Environmental Representative.

- If the fire is in an office area, personnel should be evacuated to a designated area.

- Secure the area for an investigation as to the cause and assess the damage.

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2.2 Medical

- Evaluate situation.

- Call for assistance by radio or cell phone; state nature of emergency and request notification of emergency response groups if necessary.

- If you don’t have a radio or cell phone, send the next person who arrives to telephone for help.

- Never move an injured person until the extent of injuries has been determined.

- Begin first aid treatment and continue until help arrives or the injured person is stabilized.

- People with severe injuries should be taken to a hospital by ambulance.

- People with minor injures should be taken by company vehicle to nearest medical facility.

- Do not move a person who has been fatally injured.

- Always have a boat available to take those needing medical assistance to the dock facility to await EMS.

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2.3 Natural Disasters

2.3.1 Tornadoes

Definitions:

- Tornado watch: conditions are favorable for tornado formations.

- Tornado warning: tornadoes have been sighted or indicated on radar.

Tornado Watch

- Notify employees by company radio or mobile phone.

- Tune into local radio station or NOAH weather channel on company radio.

- Watch the sky periodically.

- Ensure facility is secure.

Tornado Warning

- Notify employees by radio or mobile phone.

- Take cover in a cellar or low area, such as a ditch.

- If there is no low area available, take cover in a room with no windows.

2.3.2 Heavy Rains, Floods, Strong Winds and Lightning

- Do not gauge tanks during lightning; stay away from electrical equipment and metal equipment, like tanks.

- Do not go outside during severe thunderstorms unless absolutely necessary.

- If in a boat during an electrical storm, stay inside and take precautions.

- When flooding is expected, electrical power and main gas valves should be shut off.

- Make sure that emergency equipment (such as ESD’s) is not affected by the power shut down.

- Shut down wells and facilities as necessary.

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- Small flammable liquid storage tanks should be secured to prevent flooding and possible pipe rupture.

- Move stored items to above the anticipated water level.

- After flooding, drinking water quality may need to be verified.

2.3.3 Hurricanes

Phase I - Hurricane Alert

- Make arrangements to track the storm.

- Secure loose objects and materials.

- Determine liquid levels in tanks.

- Arrange for electrical generators or propane.

- Gather materials for securing buildings (plastic, rope, tape, batteries, tarps, etc.)

Phase II - Hurricane Threat

- Fill empty tanks with water.

- Secure buildings and begin moving office equipment to interior rooms.

- Fill vehicles with gas.

- Order electrical generators.

- Shut in wells.

- Notify customers of change in supply status.

- Allow employees who reside in areas that will be quickly affected by the storm to go home as soon as possible.

- Employees should provide phone numbers of where they can be reached after the storm has passed.

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Phase III - Evacuation

- Evacuate when local authorities recommend - Verify all facilities are shut-down and secured, and buildings are secured.

- Notify employees which radio stations will broadcast information concerning returning to work.

- Verify all personnel have left the area.

Resumption of Normal Operations

- After threat of storm has passed, assess damage and begin repairs.

- Assure safety of personnel during start-up operations.

- Allow electrical equipment to dry before re-energizing.

- Verify quality of drinking water.

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2.4 Spills

2.4.1 Oil or Produced Water

- Evaluate situation.

- Call for assistance if necessary.

- Take action to stop and contain the spill.

- Secure the area, and remove or shut-in sources of ignition.

- Contact HSE Department if their assistance is necessary.

- Foreman should ascertain the damage and collect information to pass along to the Manager such as:

Location of Spill Type of Spill (oil or chemical) Name of chemical Quantity of material Steps taken to contain the Spill

- Ensure that proper safety precautions are taken and that personal protective equipment is worn as required.

- See (SPCC Plan) Spill Prevention Control and Countermeasure Plan for specific instructions. Plans located at: Delta Duck Field Office and Houston Office, and the HSE Office in Lafayette.

2.4.2 Chemical Spills

In the event of a chemical spill, the person discovering the spill should contact the Foreman to determine the proper identification of the chemical, if the identification is not readily found on the container. Upon proper identification of the chemical, the employee should consult the Safety Data Sheet for proper handling procedures and any hazardous characteristics. Should any further questions arise call either the emergency number on the SDS or Chemtrec (800) 424-9300. SDS Book located at Delta Duck Office.

The person discovering the release will not attempt any control or containment without proper personal protective equipment.

After the appropriate personal protective equipment has been obtained and the proper procedures for control are known, containment and control procedures will be initiated. The foreman will proceed to the spill site and direct the control and containment activities. The foreman will assess the need for additional assistance and equipment. Upon assessment, the foreman will immediately contact the HSE Representative and the Manager.

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2.5 Gas/Toxic Release

- Respiratory protective equipment may be required while attempting to control a gas leak.

- Determine the cause of the leak.

- Shut down appropriate equipment.

- Sniff the area with either a combustible gas detector and/or a H2S detector to determine if the area is safe for personnel to enter without respiratory protection.

- Ensure that all sources of ignition have been removed or de-energized.

- If additional evacuation is needed, the foreman should notify Coast Guard.

- Employees should assist in evacuation efforts if needed.

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3.0 RESPONSIBILITIES

Specific responsibilities must be assigned to designate who does what activities during emergencies. Responsibilities must be assigned to individuals so that each person involved in the emergency will be aware of his/her exact duties.

EMERGENCY RESPONSE PERSONNEL RESPONSIBILITIES

Functional Area Responsibility Employee discovering the emergency - Evaluate situation. - Notify foreman. - Attempt to control situation if safe to do so. Foreman - Coordinate employee efforts in isolating and shutting down equipment and utilities. - Monitor efforts and advise employees of changing conditions. - Ensure injured employees receive medical care. - Assign individual to monitor site security. Keep by-standers and the press at the gate or other designated location. - Notify Manager of incident. -Await a company spokesperson for speaking to authorities. - Coordinate employee scheduling. - Coordinate transportation of personnel, equipment, and supplies. - Obtain necessary equipment and resources. - Ensure someone is keeping a record of events. Refer to Section 5 -- “Legal Considerations”. - Coordinate information between the field and Houston Office.

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4.0 NOTIFICATION REQUIREMENTS

The following situations required immediate notification to HSE Representative and the Manager. The notification will be made regardless of the amount of information available. Follow on reports containing additional information.

- Fatality involving employee or contractor.

- Accident which requires hospitalization of any person.

- Fire, explosion or equipment damage in excess of $5,000.

- Any fire, explosion or equipment damage which results in injury to any person.

- Incident requiring notification of regulatory agency (spills, etc.).

- All boating incidents.

- Incident that involves or potentially endangers the local community or is highly visible to the news media.

Figure 1 shows the notification sequence for incidents.

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FIGURE 1. Incident Occurs

Employee

Renders aid to Notify Foreman injured; begins to control incident

Foreman

Assures emergency services Notifies Houston Operations have been called; obtains details of incident

Manager

Notifies HSE Representative Notifies regulatory agencies as required

HSE Rep. Notifies Houston Activates Incident Command System Directs assistance as requested

NAME TITLE OFFICE MOBILE Tommy Lejeune Production Super. (337) 232-1702 (337) 315-7187 (337) 319-1916 Eugene Obrien Production Foreman (337) 761-9835 Earnest Russell (601) 590-3742 Chris Sanfilippo Environmental Manager (337) 232-1702 (830) 832-7098 Brandon Lege Health and Safety (337) 232-1702 (337) 385-8937

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5.0 INCIDENT COMMAND SYSTEM

TPIC has developed an Incident Command System (ICS) for use on major incidents. The ICS consists of three levels which include:

- On-Scene Commander - Delta Duck Field Office - Houston Office

The Houston Office acts as support elements for the on-scene commander. The TPIC ICS is shown in Figure 2.

FIGURE 2.

Houston Office When Requested

Technical

Incident Commander

Onsite Legal

Response Teams Public Affairs

- Employee Labor - Contract Labor - Specialty Contractor Human Resources - Community Organization

Land

Medical

- Community Support Safety

Safety

Environmental

Environmental Purchasing & Materials

Security

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6.0 LEGAL CONSIDERATIONS

During a large-scale emergency, a person should be designated as a recording secretary. A chronological log should be kept of how the incident proceeded. A tape recorder would be helpful in this situation. The following is a partial list of items to be documented.

1. All notifications to agencies and organizations. 2. Major incidents like explosions and injuries. 3. Media contacts. 4. Meetings - attendees, topics, decisions. 5. Activities undertaken. 6. Contacts made for the purpose of supplies and equipment. 7. Approvals or directives obtained from outside agencies or TPIC support groups. 8. Photograph the incident as thoroughly as possible during and after the event. 9. Take samples and record results to document concentrations. Try to collect samples at the same time as outside agencies.

Everything that can be documented should be documented before repairs or clean-up operations are started.

One person should be responsible for all information released (normally the Public Affairs Representative). In the event, however, that a law enforcement or regulatory agency wishes to interview persons other than the designated company spokesperson, the following guidelines should be observed by persons being interviewed:

1. One person should serve as spokesperson. This person should:

a. Have thorough knowledge of operations. b. Have sufficient authority to have credibility. c. Be personable and articulate. d. Have management approval.

2. Points to remember:

a. Periodically update the information from which you are working, especially for long-term or major incidents. b. You are never “off the record” when talking to the media or government officials. c. Avoid speculation or personal opinion. d. Have an assistant available at all times to monitor interviews and write notes on the questions and answers.

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7.0 PUBLIC AFFAIRS

The role played by the Public Affairs Representative in dealing with the media during times of crisis is extremely important. The way information is reported regarding an emergency situation can make the difference between an organization being perceived as unprepared and unconcerned about its employee’s safety, versus being viewed as a good “member of the community,” who is experiencing an unfortunate situation, but is prepared and handling that situation as well as possible. Below are helpful techniques and procedures that can be used by the Public Relations Officer: a. Establish a specific media center and confine media representatives to it. Make sure the center is out of the way of emergency work being performed by crisis management and rescue personnel. (The fact that you are establishing such a center will indicate your facility’s desire to be cooperative by setting specific space inside for the media.) b. Continue to update yourself regarding the emergency situation. Release this information to the media as quickly as possible, once its accuracy has been verified and management of the facility has been consulted. Check with facility management on the text of all announcements and help formulate the answers to possible questions. Questions to expect will concern:

- type of incident occurring - number of deaths and injuries - damage estimates - time the incident occurred - location of the incident - cause of the incident (this information should only be released after appropriate studies and investigations are performed) c. Log, record and date all statements given to the media. This will enable you to know exactly what was said to the media and when the statements were made. d. Be especially alert to photography. You have no control over photos taken away from company property, but you have every right to control pictures taken within the facility. Remember, in isolation, pictures can “misrepresent” an emergency as badly as ill-chosen words. e. Arrange for safety, labor and other appropriate employee records to be available for reference. Make sure you highlight successful safety records previously established by your facility. f. Avoid speculations as to the cause of the disaster, amount of damage, responsibility, possible down time, layoff, etc. It is often appropriate to do no more than confirm that is already known and make sure the media knows that the facility will provide all the assistance it possibly can.

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g. Never release the names of victims until it is certain that their families have been notified. Make sure that the Houston Personnel Office (or their representative) has talked directly to next of kin before names are released. h. Always accentuate the positive. If your public relations efforts are good, so will your chances be for fair treatment from the media.

7.1 Public statements should contain as appropriate:

a. The nature, time and location of the incident, and other facts that are clearly not in dispute.

b. The steps being undertaken or planned by the Company or outside agencies to control and/or repair the situation, and to prevent a recurrence. If advisable, include an estimate of the time that should be required to repair or to restore operations to normal. This may include a brief description of damage to Company property, effect on normal operations, etc.

c. The name of the official Company spokesman and general identification of other Company personnel involved in the remedial steps.

7.2 Public statements should never contain:

a. Estimates of extent of damage or the cost to the Company or any individual because of the emergency.

b. Emotional statements which may affect the state of mind of the individuals involved.

c. Any information which might mislead the public, harm individuals involved or their families, or endanger the Company’s position in legal proceedings at a future date.

Page 18 Revised 1/2017

Delta Duck Field Emergency Response Plan

8.0 TRAINING GUIDELINES

New employees and employees recently assigned will receive training on the Emergency Response Plan (ERP) from their immediate supervisor. All contract and visiting personnel will receive specific instructions of their responsibilities during an emergency situation prior to entering the facility.

Each Supervisor will be responsible for annual review of this plan, in detail, with all personnel. He will also be responsible to conduct retraining upon any addition or revision.

In addition to the annual training of the ERP, the following should be a part of the training as well.

- Hazardous Waste Operations and Emergency Response

- Hazard Communication

- Hearing Conservation

- Fire Training and Prevention

- Hydrogen Sulfide

- CPR/First Aid

- Personal Protective Equipment/Respirator Training

- Though not required, a hot weather orientation program is encouraged.

Page 19 Revised 1/2017

Delta Duck Field Emergency Response Plan

Emergency Phone Numbers

See following page.

Page 20 Revised 1/2017

From: Lee Womack To: DCRT Section 106 Cc: Barret fortier Cbarret [email protected]) Subject: Consultation Letter - LLOX, LLC Date: Friday, November 16, 2018 2:14:21 PM Attachments: iroaaeoo1.ona imaaeoo2.ona imaae003.ong imaae004.ong 18-1083SHPO.odf

M s. Sanders,

Please see attached consultation letter on behalf of LLOX, LLC.

Thanks,

Lee Womack Senior Pro j ect M anage r

Matrix /\Jew Worldr ngineen;ig 2798 O'Neal Lc..ne Buildirig f- p Jto.1 R.oug1c., ._f',, 7081f (PII· 504578.0627

**PLEASE NOTE NEW ADDRESS** MATRIX E ORLD Engineering Progress www matrixneworld com Certified WBE, DBE, SBE Business cm

Matrix New World Engineering, Land Surveying and Landscape Architecture, P.C. 2798 O'Neal Lane, Building F Baton Rouge, LA 70816 504.578.0627 www.Matrixneworld.com WBE/DBF/SBE MATRIX ORLD

November 16, 2018

VIA ELECTRONIC MAIL [email protected] No known historic properties will be dedec:I by this undertaking. Thenllor9, our office hits no objection to 1he implemelllation of this p,o;ect. This effect determination could change should ,_ information come to our attention. Ms. Kristin Sanders State Historic Preservation Officer Louisiana Office of Cultural Development tlJ,iL,'? 16 P.O. Box 44247 Baton Rouge, LA 70804-44247 Kristin P. Sanders State 1-istoric Preservation Olllcer Date 11210512018 Re: Consultation Letter Delta Duck Prospect LLO U.C Plaquemines Parish, Louisiana Matrix Pfoiect No. 18-1083

Dear Ms. Sanders:

On behalf of LLOX, LLC {LLOX), Matrix New World Engineering (Matrix) requests written documentation regarding compliance with the National Historic Preservation Act of 1966 and the Archeological and Historic Preservation Act of 1974 for the proposed Delta Duck Prospect and associated production structures in Delta National Wildlife Refuge, Plaquemines Parish, Louisiana (Figure 1).

The proposed well location is approximately 12 miles southeast of Venice, Louisiana, centered at approximate Latitude 29.233333°; Longitude -89.162500° (Figure 1). The proposed well is sited east of Dead Women Pass in open water (Figure 2). In addition to the proposed well location, LLOX is currently assessing the feasibility of several pipeline alternatives, as depicted on Figure 3, to link the proposed well to existing Texas Petroleum Investment Co. (TPIC) facilities. Upon selection of the preferred alternate, the pipeline will be installed via jetting within existing canals and bayous.

Please be advised that LLOX is currently coordinating with the U.S. Fish and Wildlife Service, Southeast Louisiana National Wildlife Refuge Complex, Delta National Wildlife Refuge Manager regarding the above referenced project as it relates to National Environmental Policy Act (NEPA) requirements.

If you agree that the implementation of the proposed project will have no effect on properties listed or

18-1083 SHPO

MATRIX ORLD Engineering Progress eligible for listing on the National Register of Historic Places, or other sensitive cultural or archeological resources, please indicate your approval and return this document, or photocopy thereof, to Matrix. Should you have any questions, or require additional information regarding this consultation letter, please contact me at (504) 578-0627 or via email at [email protected].

Sincerely,

iJ Lee Womack Senior Project Manager Matrix New World Engineering

18-1083 SHPO 2

November 16, 2018

Mr. Joseph Ranson Field Supervisor U.S. Fish and Wildlife Services 646 Cajundome Boulevard, Suite 400 Lafayette, Louisiana 70506

Dear Mr. Ranson:

On behalf of LLOX, LLC (LLOX), Matrix New World Engineering (Matrix) requests written documentation regarding compliance with the Federal Endangered Species Act of 1973 (87 Stat. 884, as amended; 16 U.S.C. 1531 et seq.) and the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661 et seq.) for the proposed Delta Duck Prospect and associated production structures in Delta National Wildlife Refuge, Plaquemines Parish, Louisiana (Figure 1).

The proposed well location is approximately 12 miles southeast of Venice, Louisiana, centered at approximate Latitude 29.233333°; Longitude -89.162500° (Figure 1). The proposed well is sited east of Dead Women Pass in open water (Figure 2). In addition to the proposed well location, LLOX is currently assessing the feasibility of several pipeline alternatives, as depicted on Figure 3, to link the proposed well to existing Texas Petroleum Investment Co. (TPIC) facilities. Upon selection of the preferred alternate, the pipeline will be installed via jetting within existing canals and bayous.

Please be advised that LLOX is currently coordinating with the U.S. Fish and Wildlife Service, Southeast Louisiana National Wildlife Refuge Complex, Delta National Wildlife Refuge Manager regarding the above referenced project as it relates to National Environmental Policy Act (NEPA) requirements.

Included for your review are: Attachment A – Endangered Species Act (ESA) Project Review and Guidance for Federal Trust Resources Report, Figure 1 – Vicinity Map, Figure 2 – Site Location Map, and Figure 3 –Aerial Photograph.

18-1083 USFWS 1

Should you have any questions, or require additional information regarding this consultation letter, please contact me at (504) 578-0627 or via email at [email protected].

Sincerely,

Lee Womack Senior Project Manager Matrix New World Engineering

18-1083 USFWS 2

LLOX, LLC

ATTACHMENT A

ENDANGERED SPECIES ACT (ESA) PROJECT REVIEW AND GUIDANCE FOR FEDERAL TRUST RESOURCES REPORT

Endangered Species Act (ESA) Project Review and Guidance for Other Federal Trust Resources Report

Instructions

Please submit a copy of this report to the Louisiana Ecological Services Office for review at [email protected]. Contact our office at (337) 291-3100 for further assistance.

Project Description: LLOX, LLC is proposing a well location (Delta Duck Prospect) and associated production structures in Delta National Wildlife Refuge, Plaquemines Parish, Louisiana.The proposed well location is approximately 12 miles southeast of Venice, Louisiana, centered at approximate Latitude 29.233333°; Longitude -89.162500° . The proposed well is sited east of Dead Women Pass in open water. In addition to the proposed well location, LLOX is currently assessing the feasibility of several pipeline alternatives to link the proposed well to existing Texas Petroleum Investment Co. (TPIC) facilities. Upon selection of the preferred alternate, the pipeline will be installed via jetting within existing canals and bayous.

Requesting Agency: Matrix New World Engineering

Project Coordinates: Latitude: 29.233333 Longitude: -89.162500

Point of Contact: Lee Womack

Address: 2798 O'Neal Lane, Building F

City: Baton Rouge State: Louisiana Zip Code: 70816

Phone Number 1: 504-578-0627 Phone Number 2:

Email Address: [email protected]

Does the proposed action only involve telecommunication structure(s)?

No

Would the proposed action occur entirely within an existing footprint or rights-of-way (ROW)?

No

Would any portion of the proposed action occur within one of these areas of interest?

No

West Indian Manatee

Does the proposed action fall within the manatee consultation zone, excluding the Mississippi River (see map), and involve in-water activities, with depths of at least 2 feet, during the months of June through November?

Yes

Is the proposed action's footprint entirely on land?

No

Would the proposed action involve in-water activities, with depths of at least 2 feet, during the months of June through November?

Yes

Would the following Standard Manatee Conditions for in-Water Activities be included within the project design?

Yes

Standard Manatee Conditions for In-water Activities

During in-water work in areas that potentially support manatees all personnel associated with the project should be instructed about the potential presence of manatees, manatee speed zones, and the need to avoid collisions with and injury to manatees. All personnel should be advised that there are civil and criminal penalties for harming, harassing, or killing manatees which are protected under the Marine Mammal Protection Act of 1972 and the Endangered Species Act of 1973. Additionally, personnel should be instructed not to attempt to feed or otherwise interact with the animal, although passively taking pictures or video would be acceptable.

All on-site personnel are responsible for observing water-related activities for the presence of manatee(s). We recommend the following to minimize potential impacts to manatees in areas of their potential presence:

• All work, equipment, and vessel operation should cease if a manatee is spotted within a 50-foot radius (buffer zone) of the active work area. Once the manatee has left the buffer zone on its own accord (manatees must not be herded or harassed into leaving), or after 30 minutes have passed without additional sightings of manatee(s) in the buffer zone, in-water work can resume under careful observation for manatee(s). • If a manatee(s) is sighted in or near the project area, all vessels associated with the project should operate at “no wake/idle” speeds within the construction area and at all times while in waters where the draft of the vessel provides less than a four-foot clearance from the bottom. Vessels should follow routes of deep water whenever possible. • If used, siltation or turbidity barriers should be properly secured, made of material in which manatees cannot become entangled, and be monitored to avoid manatee entrapment or impeding their movement.

m a n a t e e s sh o u ld be posted prior to and dur ing all in­ emoved up on comp leti on. Each vesseJ involved In d isplay at the vess.el contr ol .st at ion or in a pr ominent ees op er at ing the vesse,l a temp orary sign at least 8½ " ar to th e following: " CAUTI ON BOATERS: MANATEE RE D I N CONS RUCTI ON AREA AND WHERE THE RE IS TOM CLE ARANCE WHE N MANATEE IS P RESE NT". A uring 81/2 " X 1l." sh ould be posted at a locat ion sonnel engaged in wat er -r elat ed activit ies and sh ould f oll owing : " CAUTION: MANATEE AREA/ EQUIP ME NT I.ATEL Y IF A MANATEE COMES WIT HI N SOFEET OF

ightings of manatees sh ould be immed iat e yl r ep o rt ed to i ca l S e rv i c e s Office (337/29 1.-3 100 ) and th e Louisiana ish- eries, Nat ur al Herit age Program (225 /76S -282 1). the calf ( i.e., report of an incid ent, manatee sig h t ing, g; and the approximate locat ion, including the lat it ud e p ossib le.

osed action i s n o t l ik e yl to a d v er s e yl impact th e West

///('k /4CJ / ;s-· Ddte 7

i n this report, as well as anyp ert inent cor respond ence project file at our office (if app licab le) , th e Service th epr oposed action is not likeyl to ad verseyl imp act the

ce Date

sed action is conclud ed wh eny ou receivesgi nat ur e ued comp liance with the ESA,r einitiat:e coordinat ion

the action may impact list ed sp ecies to an extent not n;

y th at causes effects to Hsted species not considered in

e action may imp act.

Migratory Bird Conservation Recommendations

Bald Eagle

The proposed project area may provide nesting habitat for the bald eagle (Haliaeetus leucocephalus), which was officially removed from the List of Endangered and Threatened Species as of August 8, 2007. However, the bald eagle remains protected under the Bald and Golden Eagle Protection Act (BGEPA) (54 Stat. 250, as amended, 16 U.S.C. 668a-d) and theMigratory Bird Treaty Act (MBTA) (40 Stat. 755, as amended; 16 U.S.C. 703 et seq.) The Louisiana Department of Wildlife and Fisheries (LDWF) has not collected comprehensive bald eagle survey data since 2008, and new active, inactive, or alternate nests may have been constructed within the proposed project area since that time.

The Service developed the National Bald Eagle Management (NBEM) Guidelines to provide landowners, land managers, and others with information and recommendations to minimize potential project impacts to bald eagles, particularly where such impacts may constitute “disturbance,” which is prohibited by the BGEPA. A copy of the NBEM Guidelines is available at: http://www.fws.gov/migratorybirds/pdf/management/nationalbaldeaglenanagementguidelines.pdf

In southern Louisiana parishes, eagles typically nest in mature trees (e.g., baldcypress, sycamore, willow, etc.) near fresh to intermediate marshes or open water. Bald eagles may also nest in mature pine trees near large lakes in central and northern Louisiana. If a bald eagle nest occurs or is discovered within 660 feet of the proposed project area, then an evaluation must be performed to determine whether the project is likely to disturb nesting bald eagles. That evaluation may be conducted on-line at: https://www.fws.gov/southeast/our-services/eagle-technical-assistance. Following completion of the evaluation, that website will provide a determination of whether additional consultation is necessary.

Colonial Waterbirds

In accordance with the Migratory Bird Treaty Act of 1918 (as amended), please be advised should the project area be located in or near wetland habitats which may be inhabited by colonial nesting waterbirds and/or seabirds, additional restrictions may be necessary.

Colonies may be present that are not currently listed in the database maintained by the Louisiana Department of Wildlife and Fisheries. That database is updated primarily by (1) monitoring previously known colony sites and (2) augmenting point-to-point surveys with flyovers of adjacent suitable habitat. Although several comprehensive coast-wide surveys have been recently conducted to determine the location of newly-established nesting colonies, we recommend that a qualified biologist inspect the proposed work site for the presence of undocumented nesting colonies during the nesting season because some waterbird colonies may change locations year-to-year. To minimize disturbance to colonial nesting birds please refer to our colonial nesting waterbird guidance on the LESO Webpage https://www.fws.gov/lafayette/Migratory_Birds/MigBird.html.

Additional Migratory Bird Conservation Recommendations

During the project impact analysis process developers should identify project-related impacts to migratory birds and the conservation measures that will be used to mitigate them. For additional Migratory Bird Conservation recommendations, guidance and tools to help reduce impacts to birds and their habitats please visit the LESO webpage https://www.fws.gov/lafayette/Migratory_Birds/MigBird.html and the Service’s Migratory Bird Program Webpage (https://www.fws.gov/birds/bird-enthusiasts/threats-to- birds/collisions/communication-towers.php).

LLOX, LLC

FIGURES

^_ £

Project Center Latitude 29.233333° Longitude -89.162500°

!

Legend ● Proposed Delta Duck Prospect Vicinity Map

Delta National Wildlife Refuge Consultation Letter Delta National Wildlife Refuge, Plaquemines Parish, Louisiana LLOX, LLC Delta Duck Prospect 4 2 0 4 Miles Drawn By CET Approved By LAW Source: Base map comprised of ESRI StreetMap USA data. National Wildlife Refuge (NWR) Date 11/16/2018 1 data obtained from U.S. Fish and Wildlife Service, Division of Realty. Drawing No. 18-1083-A001 Figure No.

£

Project Center Latitude 29.233333° Longitude -89.162500°

!

Legend ● Proposed Delta Duck Prospect Site Location Map

Consultation Letter Delta National Wildlife Refuge, Plaquemines Parish, Louisiana LLOX, LLC Delta Duck Prospect 2,000 1,000 0 2,000

Feet Drawn By CET Approved By LAW Source: Base map comprised of U.S.G.S. 7.5-minute topographic map(s), "Main Pass, LA" Date 11/16/2018 2 dated 1971; and "Pass A Loutre West, LA" dated 1993. Drawing No. 18-1083-A002 Figure No.

!! £

!!

!!

Legend Site Plan Proposed Delta Duck Proposed Pipeline Route !! Prospect Alternates Consultation Letter !! Existing TPIC Facility Alternate 1a Delta National Wildlife Refuge, Plaquemines Parish, Louisiana !! Existing TPIC Well Alternate 1b Proposed Delta Duck Alternate 2a LLOX, LLC Prospect Keyway Alternate 2b Delta Duck Prospect Alternate 2c 2,000 1,000 0 2,000 Feet Alternate 2d Drawn By CET Approved By LAW Source: Base map comprised of 2017 aerial photography from USDA/FSA Aerial Photography Date 11/16/2018 3 Field Office, National Agriculture Imagery Program (NAIP). Drawing No. 18-1083-A003 Figure No.

Lee Womack

From: Johnna Fisher Sent: Thursday, February 14, 2019 12:09 PM To: Lee Womack Subject: Delta Duck Prospect , LLOX, LLC, Plaquemines Parish, LA Matrix Project No. 18-1083

Mr. Womack, Regarding the above-mentioned project, the Jena Band of Choctaw Indians' THPO hereby concurs with the determination of No Adverse Effect; Should any inadvertent discoveries or anticipated impacts occur, please contact all Tribes with interest in this area . Thank you. Sincerely, Johnna Fisher

Johnna Fisher Jena Band of Choctaw Indians THPO & Cultural Dept. P.O. Box 14 Jena, La 71342 (0) 318-992-1205 (F) 318-992-8244 jfi sher@ jenac hoctaw.org

1

Lee Womack

From: Lee Womack Sent: M onday, March 11, 2019 11:02 AM To: 'Lindsey Bilyeu' Subject: RE: Delta Duck Prospect, LLOX, LLC, Plaquemines Parish, LA

Thanks Lindsey.

Sorry for the delayed response I was on vacation last week.

Since all the project impacts occur in open water we were not intending to do a Cultural Resource Su rvey. Additionally, the State (SHPO) provided concurrence for the project and did not request a survey.

Thanks,

Lee Womack Senior Project Manager

Matrix New World Engineering 2798 O'Neal Lane, Building F Baton Rouge , LA 70816 C: 504.578 .0627

O frn @) You MAI' RIX ORLD Eng in eeri ng Pro gress www.matrixneworld.com Certified WBE, DBE Business

From: Lindsey Bilyeu Sent: Wednesday, March 6, 2019 10:25 AM To: Lee Womack Subject: RE: Delta Duck Prospect, LLOX, LLC, Plaquemines Parish, LA

M r. Womack,

The Choctaw Nation of Oklahoma thanks you for the correspondence regarding the above referenced pro ject. Plaquemines Parish lies in our area of historic interest. Will a cultural resources survey be planned for the project area?

If you have any questions, please contact me.

Thank you,

Lindsey D. Bilyeu, MS Senior Compliance Review Officer Historic Preservation Department Choctaw Nation of Oklahoma 1

P.O. Box 1210 Durant, OK 74702 580-924-8280ext . 2631

Choctaw Nation .t±t-.tti .,.,. ..U .H ·.t ±t ±t:t: F,:11 t h • l -.;1rn i ly • ::::u l tu re ® This message is intended only for the use of the individual or entity to which it is addressed and may contain information that is privileged, confidential and exempt from disclosure. If you have received this message in error, you are hereby notified that we do not consent to any reading, dissemination, distribution or copying of this message. If you have received this communication in error, please notify the sender immediately and destroy the transmitted information. Please note that any view or opinions presented in this email are solely those of the author and do not necessarily represent those of the Choctaw Nation.

2

STATUES, EXECUTIVE ORDERS, AND REGULATIONS

Cultural Resources

National Historic Preservation Act of 1966, as amended, 16 U.S.C. 470- 470x- NHPA requirements have been addressed via the State 6; 36 CFR Parts 60, 63, 78, 79, 800, 801, Historic Preservation Officer for Louisiana (Appendix F) and 810

Fish & Wildlife

Endangered Species Act of 1973, as amended, 16 U.S.C. 1531-1544; 36 CFR ESA requirements have been addressed via the USFWS Part 13; 50 CFR Parts 10, 17, 23, 81, Lafayette Ecological Services Field Office (Appendix G) 217, 222, 225, 402, and 450

Water Resources

Coastal Zone Management Act of 1972, 16 U.S.C. 1451 et seq.; 15 CFR Parts 923, 930, 933 Compliance with applicable water resource statutes, executive orders and regulations will be covered within Rivers and Harbors Act of 1899, as the Louisiana Department of Natural Resources, Office amended, 33 U.S.C. 401 et seq.; 33 CFR of Coastal Management, Joint Permit Application for Parts 114, 115, 116, 321, 322, and 333 work within the Louisiana Coastal Zone and the U.S. Army Corps of Engineers Section 10/404 permitting process. Executive Order 11990 – Protection of Wetlands, 42 Fed. Reg. 26961 (1977)

APPENDIXJ

FIELD INSPECTIONS AND OTHER STUDIES, ANALYSIS OR PERMITS USED TO COMPLETE EA OR PROCESSING PERMITS

Field Inspection:

To date no field inspection has been completed by USFWS.

Additional Studies Performed as a Result of this Permit Request or Used in Writing this EA: N/A

List of Other Permits Applied for/Obtained by the Applicant:

The Applicant must have all obtained all other necessary permits before they can begin operations on the refuge. The Applicant has applied to or will obtain the following permits:

1. Coastal Use Permit – U.S. Army Corps of Engineers & Louisiana Department of Natural Resources, Office of Coastal Management 2. Plaquemines Parish Work Permit (Plaquemines Parish Government) 3. Application for Permit to Drill from Louisiana Department of Natural Resources