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Copyright 1999 Federal News Service, Inc.  
Federal News Service

JANUARY 27, 1999, WEDNESDAY

SECTION: IN THE NEWS

LENGTH: 7507 words

HEADLINE: PREPARED TESTIMONY OF
MARK VAN PUTTEN
PRESIDENT AND CEO, NATIONAL WILDLIFE FEDERATION
BEFORE THE SENATE ENERGY AND NATURAL RESOURCES COMMITTEE
SUBJECT - AMERICA'S COASTAL RESOURCES:
VALUABLE AND VULNERABLE

BODY:

Mr. Chairman, Senators, thank you for this opportunity to testify before you. My name is Mark Van Putten; I am here today on behalf of the National Wildlife Federation, the Nation's largest conservation advocacy and education organization.
My testimony' outlines some of the threats that our invaluable coastal resources face as a result of offshore oil and gas drilling -- in particular, drilling on the Outer Continental Shelf (OCS). It is hard to overstate the devastating environmental impacts of OCS drilling -- impacts that result from the initial exploration and development of the platforms; from the production, transportation, and refining of oil and gas; and ultimately, from our own consumption of OCS petroleum. Unfortunately, the lion's share of these impacts are borne by America's coastal zones, which rank among the most biologically rich and economically significant natural systems on the continent. These coastal zones are home to over half the Nation's population, play a critical role in absorbing flooding and blunting storms, provide important spawning habitat for commercially valuable fisheries, and harbor a disproportionate fraction of rare and endangered wildlife.
Thoughtful analysis of this issue quickly reveals three underlying facts:
1) petroleum and petroleum by-products are an integral part of our economy;
2) these products are toxic to nearly every type of living organism; and
3) once freed from the earth's crust, these substances are virtually impossible to completely contain -- in small and large quantities, they leak, spill, and evaporate, with environmental effects that are felt far from the rigs that bring them to the surface.
The impacts of OCS drilling are substantial and widespread. Some of these impacts are so severe that there is no hope for mitigation or restoration, however, many others can and should be addressed. Indeed, there are real opportunities to mitigate and restore some of the coastal resources that have been degraded and protect existing resources from future degradation. Senate bill, S. 25, the "Conservation and Reinvestment Act of 1999," that was recently introduced by Senators Murkowski, Landrieu, and others, proposes to redirect revenue generated from offshore oil and gas drilling for conservation and other purposes. Amendments to S. 25 are necessary to ensure that it fulfills its potential for addressing the conservation impacts described in this testimony and that the bill in no way creates incentives for increasing OCS drilling.
Overview of OCS Drilling
Currently, there are approximately 3,800 oil and gas drilling platforms along the U.S. federal Outer Continental Shelf (National Research Council, 1996). Although drilling platforms are found on the coasts of 6 states (California, Alaska, Texas, Louisiana, Alabama, and Mississippi), they are most heavily concentrated in the waters off of Louisiana and Texas. Cumulatively, this drilling accounts for approximately 18% of domestic oil and 27% of domestic natural gas production (Quarterman, 1998).
Florida, California, Oregon and Washington have banned new leasing in state waters (and there are existing leases in Florida and California that have not yet been developed). With the exception of some areas off of Florida, Alabama, and Alaska, nearly all remaining coastal areas have been withdrawn by President Clinton from new oil and gas leasing through the year 2012. This moratoria also applies indefinitely to all areas designated as marine sanctuaries. To date, 12 sites have been designated marine sanctuaries, including one -- the Flower Garden Banks -- in the Gulf of Mexico. The OCS moratoria does not affect existing leases and drilling on existing leases shows no signs of abating. In fact, the Minerals Management Service (MMS) notes that development of the OCS is expected to increase substantially over the next few years, in part due to growing interest and activity in the area of deepwater drilling (MMS, "Deepwater," 1999; Year of the Oceans Report, 1998). Furthermore, over half the Nation's undiscovered oil and gas reserves are believed to occur on the OCS, and the pressure to drill in existing lease areas is likely to increase as oil resources become depleted (Year of the Oceans Report, 1998).
The OCS program generates bonuses, rent, and royalty payments to the Federal Treasury of nearly $4-5 billion annually (with a cumulative historic total of $120 billion, as of 1998) (Quarterman, 1998). A portion of these funds is distributed to coastal states that have OCS drilling sites off of their coasts (under section 8(g) of the OCS Lands Act -- in 1998 $65 million went to six coastal states). Some of these OCS receipts are also used to fund the Land and Water Conservation Fund (over $19 billion to date) and the National Historic Preservation Fund (nearly $3 billion to date) (Quarterman, 1998).
The following discussion of the destructive impacts of OCS oil and gas drilling argues strongly for mitigation and conservation practices that offset, where possible, the impacts of current OCS drilling.
Threats Posed by OCS Drilling
If asked to reduce Outer Continental Shelf (OCS) drilling to a single visual image, most people would picture an oil rig, silhouetted against the sky, in the middle of open ocean. In fact, while oil rigs do have significant environmental impacts by themselves, the rigs are just one step in a long process of production, refining, distribution, and consumption. Impacts of OCS drilling on the coastal zone arise at all stages of this process, from pre-production exploration and rig- construction, to refining, to transportation of oil and gas by pipeline and tanker, and ultimately to consumption patterns shaped by the availability of OCS petroleum.
Oil Exploration and Rig Construction
From the outset, offshore exploration has significant environmental consequences. Seismic surveys used in oil and gas exploration generate sound waves that are known to disturb various marine mammals, as well as other marine species. For example, seismic waves are believed to interfere with gray whales' ability to communicate with one another and they demonstrate behavioral changes in response to seismic pulses.
Development of the rigs and related structures also has substantial environmental repercussions. Laying down pipelines, anchoring rigs to the ocean bottom, and other related construction activities generally result in mechanical damage to the underlying sea floor and can have devastating impacts on ecologically sensitive habitats such as coral reefs and sea grass beds (MMS, 1999; DO1, "Notice to Lessees and Operators 98-12," 1998). Newly discovered deep-sea benthic communities of unique chemosynthetic organisms (which include assemblages of tubeworms, clams, mussels, and other species) face significant threats from the rapid increase in deepwater ocean drilling (DOl, "Notice to Lessees and Operators 98-11," 1998).

The accompanying noise, increased boat and air traffic, and debris generated during the construction of these sites have also been found to disturb the surrounding marine ecosystem and marine species that inhabit the area. Sea otters, for example, have been observed avoiding areas where construction is ongoing and have reacted negatively to recorded playbacks of platform construction sounds (MMS, 1999).
Interestingly, scientists are beginning to discover that the deconstruction of these structures also presents serious environmental challenges. Approximately one-quarter of the existing offshore platforms are over 25 years old and many of them will have to be decommissioned over the 'next 10-15 years (National Research Council, 1996; MMS, 1999). To date, the vast majority of decommissioned rigs were broken into pieces -- through the use of underwater explosives -- so that the smaller pieces could be carried away. Unfortunately, these' underwater explosives have significant detrimental impacts on endangered sea turtles and marine mammals. These explosions have also been found to cause substantial fish kills (National Research Council, 1996). As the large number of platforms built in the 1960's and 70's become ready for decommissioning, this issue will become a more serious problem.
Subsidence and coastal marsh destruction
Louisiana boasts 40 percent of the coastal and estuarine wetlands in the Lower 48 states, but accounts for 80 percent of estuarine wetlands loss (Boesch, et al, 1994; Louisiana Coastal Wetlands Conservation and Restoration Task Force, 1993). The state's marshes are sinking into the Gulf at a rate of 25-35 square miles per year (Louisiana Coastal Wetlands Conservation Task Force, 1998). In part, Louisiana's coasts are subsiding as a direct result of our efforts to control the Mississippi River. Levees built and maintained by the U.S. Army Corps have imprisoned the great river in its banks and defeated its natural delta-building efforts, forcing the Big Muddy instead to drop its sediments into the abyss off the continental shelf.
Oil and gas development on the OCS, however, also bears substantial responsibility for coastal subsidence. Studies by government and academic scientists have persuasively documented that laying of pipelines and opening of navigation channels through Louisiana's coastal wetlands has accelerated erosion and subsidence. As a 1987 biological report by the U.S. Fish and Wildlife Service noted, "(w)here canal density is high, land loss is high; where canal density is low, land loss is low; where canal density is nearly zero, land loss is nearly zero .... (C)oastal erosion rates are directly related to canal and spoil levee density." CLISFWS, 1987, 28-29).
Many, if not most, of these channels were built to facilitate oil and gas exploration, placement of pipelines, or transport of rig components out into the Gulf. As the Louisiana Coastal Wetlands Conservation and Restoration Task Force explained in 1993:
The dredging of smaller channels for drilling rig access and pipeline installation proliferated in the coastal wetlands of Louisiana during the oil and gas exploration and development boom of the 1950's, 1960's, and 1970's. When onshore fields were developed, the marsh was broken up by dense canal networks. Offshore fields also caused destruction as pipeline canals were dredged through the marshes and barrier islands to connect with onshore processing facilities. By 1978, more than six percent of Louisiana's coastal wetlands had been directly converted to open water or spoil through canal dredging (Louisiana Coastal Wetlands Conservation and Restoration Task Force, 1993).
As the Coalition to Restore Coastal Louisiana notes, "coastal Louisiana is laced with about ten thousand miles of canals excavated to service the oil and gas industry." (Coalition to Restore Coastal Louisiana, 1989)
Ongoing Pollution from Drilling
In addition to the destruction caused in developing the infrastructure on and offshore for OCS drilling, routine platform operations create multiple chronic pollution sources, including: drilling muds and cuttings, produced waters/toxic oil brine, deck drainage fluids, air emissions of hydrocarbons (from the rig machinery, helicopters, and support vessels), naturally occurring radioactive materials (NORMs), and a large mount of trash produced during general rig operations.
Toxic chemicals are routinely used to lubricate drill bits as they grind through the outer continental shelf. These fluids and lubricants mix with rock and mud to form a toxic sludge (or drilling waste) that is often found hundreds of meters from the rigs. This sludge is left directly on the ocean floor, where it both suffocates and poisons benthic species found in the area. It is estimated that up to 8,000 square feet per well may be covered by up to a meter thick of drilling wastes. The National Academy of Sciences estimates that drilling produces an average of 1,500-2,000 tons of drilling waste per well (National Research Council, 1983). The waste contains toxic pollutants such as lead, arsenic, copper, mercury, petroleum hydrocarbons, selenium, and other heavy metals.
Toxic brine or "produced water" is contaminated water brought up along with oil from the well. This "produced water" is generated in massive quantities by offshore oil wells and contains a variety of pollutants, including cadmium, benzene, napthalene, lead, and other carcinogenic pollutants. Additionally, naturally occurring radioactive materials (NORMs) found deep in the earth's crust leach into produced water and are then brought to the surface as a result of the drilling.
"Workover fluids" containing oil and grease also include napthalene, ethylbenzene, toluene and zinc. While there are restrictions about dumping these work materials into the ocean, the limitations are only applied to the oil and grease directly. Other toxic materials are dumped into the ocean. Deck drainage of oil, grease, drilling fluids, ethylme, lubricants, fuels, biocides, surfactants, detergents, solvents, dispersants, coagulants and other substances are also believed to cause harmful environmental impacts when they leak or are disposed of in the ocean.
Once in the ocean, toxics can remain suspended as solids in the water column where they lead to fish kills and interfere in the development of fish eggs and larvae. In fact, this waste can remain in the ecosystem for decades causing negative impacts to marine water quality and marine species (often by disrupting the ecosystem's balance through changes in species abundance and richness). For instance, a recent study found that increased levels of sediment contamination resulted in reduced genetic diversity of small copepod species found near the offshore platforms (Street and Montagna, 1996). MMS has noted that gray whales and other imperiled marine species may be vulnerable to adverse impacts from these drilling wastes -- in particular, it is believed that it can cause eye irritation to gray whales migrating through the area. Filter feeders and bottom-feeders like corals, clams, oysters, and lobsters have been found to be particularly vulnerable to the 'effect of these toxics. This waste material strips surrounding water of its oxygen leading to reduced dissolved oxygen concentrations that interfere with fish egg development and cause other problems in the ecosystem (Holing, 1990). Toxics prove immediately lethal to some marine organisms, however they also are threatening when they accumulate in concentrated levels in the tissues of species at the top of the food chain -- including species consumed by humans.
Trash and debris, generated as a result of daily ongoing human activities has proven to be a significant problem on the sea floor and washed up as detritus on beaches in the Gulf. Remnants of construction-related debris (e.g. pipes, tubing, hard hats, lumber) and non-biodegradable environmentally persistent materials (e.g. plastic and glass) accumulate on the sea floor around figs. The U.S. Department of Interior recently issued a notice to lessees and operators of offshore figs noting that "marine trash and debris pose a threat to fish and wildlife.., oil and gas operations in the Gulf of Mexico contribute to this chronic problem" (DOI, "Notice to Lessees and Operators 98-27," 1998). This trash can be fatal for species if it is ingested or results in entanglement, whether in open waters or along coastal beaches and wetlands. The production of these rigs also, at times, leads to the emission of toxic air pollutants such as hydrogen sulfide, nitrogen oxides, carbon dioxide, and sulphur dioxide. These air toxics are known to be harmful to humans and are probably harmful to wildlife species (DOI, "Notice to Lessees and Operators 98-16," 1998).
Accidents and Disasters
Accidents and human error lead to leaks, spills, blowouts, tanker/barge collisions, burst pipelines, and explosions. Large spills caused by catastrophes such as tanker collisions, or platform blowouts are relatively rare; MMS statistics show that approximately 61,500 barrels have been spilled since 1980 (Year of the Ocean Report, 1998).

When these larger spills do happen, however, their impacts are often catastrophic and long-lasting. Despite some improvements in cleanup technologies, often only a limited amount of the spilled material can be captured before it enters the ecosystem. For example, in a recent spill in Texas involving 2,950 barrels of oil, over 1,150 barrels were never recovered (Tunnell 1995). In drilling, pockets of oil are often punched through before the actual well is tapped, leading to leakage. Blowouts occur when a drill head pierces a pressurized pocket of natural gas, and the pressure forces the drill back out of the opening, in turn blowing the contents up to the surface and sometimes destroying the rig.
More common are the smaller, chronic spills that occur as leaks. Approximately 16,000 miles of pipelines serve as the primary mechanism for conveying oil and gas from OCS platforms to the shore (Alvarado, Anderson, and Schneider, 1992). In the early 1990's it was estimated that spills from pipelines accounted for the release of approximately 4,170 barrels of oil annually, usually as the result of pipeline corrosion or pipeline disruption by ship anchors (Alvarado, Anderson, and Schneider, 1992). These types of spills can go unnoticed for days (e.g. in January 1990, 14, 423 barrels of oil leaked from a pipeline for 13 days before the slick was noticed) (Alvarado, Anderson, and Schneider, 1992). It is expected that these types of pipeline leaks will increase as the pipelines in the Gulf of Mexico and elsewhere age and become more vulnerable to corrosion.
A fair amount of spillage also occurs regularly during the process of "lightering" where crude oil is transferred from huge tankers to smaller ships. Off the coast of Texas, lightering operations have increased by 200% since 1986, raising the possibility of a big spill and ensuring chronic leakage.
Cumulatively, the common and uncommon accidental spills affect water quality, coastal and benthic habitats, and wildlife. MMS has noted that oil spills pose a number of risks to cetaceans, and studies have shown that contact, inhalation, and ingestion of oil-related compounds produces behavioral changes and physiological damage (MMS, 1999). In particular, it is believed that the toxic, highly volatile components of fresh crude is damaging to the soft tissues and mucous membranes in the eyes and airways of cetaceans, resulting possibly even in death (MMS, 1999). A study of the effects of oil on baleen, the plates that certain whales use to filter their food, found that it contaminated their plates and hindered feeding (MMS, 1999). Studies and analyses have indicated that when endangered sea turtles are exposed to oil they suffer from carcinogenesis, increased parasitism, decreased lung capacity, digestive problems, and disruptions to their sensoryorgans (MMS, 1986).
Sea otters, sea birds and other marine species are particularly vulnerable to the devastating impacts that oil contamination has on their fur and feathers. Otters must maintain a layer of warm dry air in their dense underfur to insulate them from the cold water; even partial oiling of their fur leaves them essentially exposed to the elements. In the Exxon Valdez oil spill, well over 1,000 otters were killed as a result of pulmonary empbysema caused by inhalation of toxic fumes, hypothermia from decreased insulation (as a result of fur contamination), hypoglycemia caused by poor gastrointestinal function (from ingestion of oil), and lesions on other organs (from ingestion of oil and/or stress). Oil spills often also kill animals by driving away or killing crucial organisms lower on the food chain (e.g. krill, kelp) that constitute their prey base.
Some of these chemicals have longer-term, more insidious effects. Polycylic Aromatic Hydrocarbons (or PAHs) are a group of chemicals that are released into the marine environment as a result of oil spills, discharges from ships, and other methods. Spills have received a great deal of attention recently because they have been found to have carcinogenic and mutagenic potential in finfish, shellfish, and marine mammals. They are also considered a priority pollutant by the World Health Organization, the U.S. Environmental Protection Agency and others because of their potential impacts on human health (Hellou, 1996). Spills and other toxic pollutants can remain in an ecosystem for decades after their initial release.
Although some of the oil released in spillsly settles into the bottom sediments, much of it is carried up to the coastal margin where it can cause numerous problems. Field studies have found that successive oilings of salt marshes, resulted in considerable changes to species distribution and balance, leading to slow recovery, even years later (Baker, 1973). A more recent study estimated that full f a marsh habitat in San Patrieio County Texas would take 810 years (Tunnell 1995) despite fairly dramatic cleanup methods. Other studies found that after 3 years, marsh grass was still unable to re-establish itself and sediments continued to show high levels of hydrocarbons (Hampson 1978).
The biggest externality: Climate Change and Rising Sea Levels
As substantial and diverse a set of direct impacts as OCS drilling has, surely the most significant long-term effect of OCS production for the coastal zone is its contribution to anthropogenic climate change' and sea-level rise. At present, though climate scientists remain unsure how quickly to expect temperatures to increase, a strong consensus has emerged within the scientific community that human- induced climate change is real, is in progress, and will almost certainly lead to accelerated sea-level rise. The Intergovernmental Panel of Climate Change suggests that sea-level may increase by between 20 and 86 cm over the next century. EPA has calculated a range of estimates, suggesting that there a 50% probability that sea-levels will rise at least 23 cm (one foot) by 2050 and 55 cm (two feet) by 2100 (Titus, 1998).
Since the 1950s, humans have contributed to an 8% increase in the concentration of carbon dioxide in the Earth's atmosphere. Today, the U.S. is the world's leading emitter of carbondioxide, contributing about 23% of 'global energy-related carbon emissions' -- 98.5% of which is attributed to the combustion of fossil fuels (U.S. Department of Transportation, 1998). To be sure, OCS production accounts for only a fraction of the fossil fuel consumed by Americans. Nonetheless, the marginal contribution of OCS oil and gas to climate change and sea- level rise comprises an economic externality that effects the coastal zone disproportionately, and for which impact-reduction funds have never been made available. In particular, EPA has estimated that an increase in sea level of 50 cm could inundate more than 5000 square miles of current 'uplands' and 4000 square miles of wetlands (Czardiner, D., 1996). For a point of comparison, that is six times larger than the state of Rhode Island -- an area six times the acreage that Louisiana has already lost to accelerated coastal subsidence since the 1950s (approximately 1,500 square miles) (Boesch, 1994).
The Coastal Resources at Stake
Unquestionably, our Nation's important coastal resources face a variety of threats from sources other than offshore oil and gas drilling, however, the pollution and environmental degradation just described contribute significantly to the problem. OCS drilling degrades open water habitats -seagrass beds, coral reefs, and deep sea communities -- through pollution and physical destruction that occurs during platform/pipeline construction and gas production. Additionally, OCS drilling and related activities harm coastal and estuarine wetlands, as well as barrier islands, through excavation for navigation and pipelines. These resources are also impacted directly by oil spills and trash that washes up along the shore.
The section below describes five categories of distinct and valuable coastal resources, each of which is substantially impacted by OCS drilling. The purpose of describing these resources in some detail is to highlight their unique characters and values and to articulate the oft-overlooked ecological services that they provide.
Estuarine and Coastal Wetlands
Coastal wetlands absorb and temper the impact of storm surges and protect economically significant coastlines. For example, according to one estimate, the.elimination of one mile of wetlands along Louisiana's 250 mile coastline would cause approximately $63,676 in increased hurricane damage annually (1980 dollars) (Farbet, 1987). The low gradient of many shorelines and the capacity of wetlands vegetation to absorb and dissipate wave energy combine to counteract storm surges and prevent shoreline erosion.
When Hurricane Andrew buffeted the shores of Florida and Louisiana in 1992, the Nation was reminded of the tremendous buffer coastal wetlands can provide. The storm hit both states with approximately the same strength, yet Florida, which has lost 9.3 million acres of its original wetlands (the largest acreage loss of any state), sustained between $15 to $30 billion in damage compared to the $1 billion sustained by Louisiana, with its large coastal wetlands buffer. The flood insurance claims that were paid in the wake of the hurricane came to $115 million in Florida, as compared to $30 million in Louisiana (Kusler and Larson, 1993). While other factors also played a role, the value of coastal and estuarine wetlands as buffers is evident.

Estuarine and coastal wetlands provide important water quality benefits as well. Wetlands act as "nature's kidneys," (Kusler, 1994), filtering polluted waters, removing and retaining nutrients, processing organic wastes, and reducing sediment loads to receiving waters. Water entering estuarine wetlands is slowed by aquatic vegetation growing in and around the wetland. Wetland plants and micro-organisms then go to work on wastes in the water, absorbing them into plant tissue or simply converting them into harmless forms. Compounds containing nitrogen are broken down into products useable by plants, and bacteria convert much of the nitrogen gas that escapes into the atmosphere.
Finally, coastal and estuarine wetlands provide vital habitat for wildlife. The 'coastal fringe' in fact provides habitat to a surprisingly large number of threatened and endangered species -- as of 1991, 20 federally listed species lived under the 10 foot contour (that is, no higher than 10 feet above sea level) and nowhere else, with another 33 species on the waiting list for listing as candidate species. As many as 122 listed threatened and endangered species relied on coastal and estuarine habitats (Reid and Trexler, 1991).
Coastal and estuarine wetlands sustain the abundant creatures as well as the rare. Wetlands are the cradle of the Nation's seafood industry. Fish and shellfish depend on estuaries for spawning and nursery grounds, food production, and migration. Depending on the region of the country, the percentage of' wetland-dependent fish species varies. For example, 98% of all species in the commercial seafood harvest in the Gulf of Mexico spend part of their lives in wetlands and marshes. In the southeastern U.S. this percentage is slightly lower -- 94%. The connection between wetlands and seafood is most simply illustrated by a bumper sticker frequently seen in coastal North Carolina, which succinctly states the importance of wetlands to the fishing industry -- "No Wetlands, No Seafood."
The annual economic value of estuarine habitats is presently well over $14 billion. In the late 1980's, commercial landings of estuarine- dependent species contributed some $5 billion to the economy. In California alone, the value of commercial fish landings exceeds $126 million per year, and the industry contributes $111 million per year in value=added products. The Great South Bay, a shallow tidal estuary in New York, has extensive naturally productive habitat that has contributed approximately 92% of New York's commercial hard clam landings with a reported dockside value in excess of $16.7 million (Fox, 1981). The marshes of Louisiana produce an annual commercial catch worth over $680 million (Boesch,. 1994). Despite the tremendous contribution wetlands make to our economy, over half of the wetlands that historically supported America's fisheries have been destroyed.
The economic and natural values of Louisiana's coastal wetlands -- which number among the American marshes hardest hit by OCS drilling -- are particularly striking. Louisiana marshes sustain nearly one-third of the nation's commercial fish catch, "second only to Alaska in terms of total biomass of fisheries landings, and third in terms of economic value." The state's wetland-dependent furbearers (nutria and muskrat) account for 40% of the annual national fur harvest. Recreational hunting, fishing, and outdoor activities in the marshes contribute $338 million to the state's economy annuals; about 4 million ducks, or 20% of the North American population, spend their winters in Louisiana's marshes (Boesch, 1994).
Seagrass Beds
Seagrass beds are underwater "meadows" that occur in isolated pockets offshore, where they provide vital foraging and spawning habitat for commercially important finfish and shellfish, and also sustain wintering and migrating waterfowl. Historically, seagrass beds flourished, as salinity and wave energies permitted, in sites along the full arch of the Gulf Coast, from the southern tip of Florida (Florida Bay) through the U.S.-Mexican border. Nonetheless, most estuaries in the Gulf have suffered a loss of between 20 and 100 percent of their seagrass beds, primarily as a consequence of declining water quality (HandIcy, 1995, 273).
For over two decades, we have known that seagrass beds play a role in coastal ecosystems that their low profile on the landscape makes it easy to overlook:
Documentation now exits which shows that seagrass meadows are not only important locally, but also on a much larger scale. For example, they are used as nursery grounds for commercial shrimp in Florida; as a food source for migratory waterfowl, particularly the black brant, along the Pacific flyway; and (for) green seaturtles in the Caribbean; as a habitat for the larval development and commercial bay scallops along the Atlantic coast of the United states and fishes along all coasts where the grass is present, and as a buffer from hurricanes along the Florida coast (Thayer and Phillips, 1977).
Seagrass beds are similarly important for softshell and razor clams, lobsters, and mud crabs along the Atlantic coast and for virtually the entire commercial fishery of Puget Sound (Thayer and Phillips, 1977). Off Florida, seagrass beds are key feeding grounds for the federally- listed endangered manatee, as well as the endangered Kemp's ridley sea turtle and the threatened green sea turtle (Weber, et al, 1992). Though seagrass beds have been in decline along much of America's coastline, Louisiana has experienced particularly extensive losses of its historic seagrass beds. Today, seagrass beds survive off the Louisiana coast at only one cluster of sites, Chandeleur Sound. Perdido Bay in the panhandle of Florida has also suffered substantial loss of seagrass beds,, attributed to dredging, polluted runoff from agriculture, and residential, commercial, and industrial development (HandIcy, 1995, 274).
Barrier Islands
Coastal barrier islands are complexes of beaches, dunes, and wetlands that lie offshore of the main coastline. Their chief characteristic is change: currents deposit and carry away sand and so the islands are constantly shifting shape or even migrating along the coast. Some barrier islands arequite large, with complex and unique biological communities --the maritime forests of North Carolina's barrier islands are one example; other barrier islands are quite small sandbars submerged at the highest tides. All barrier islands help to protect waterfront communities; the larger islands also provide essential habitat for a variety of wildlife, including sea turtles, birds, and small mammals. Coastal barriers act as natural buffers against storms, erosion, wind and waves.
Coastal development presents a severe threat to barrier islands (Pilkey and Dixon, 1996). On large islands, development includes residential, commercial, and public works construction, often heavily supported by federal subsidies. Indeed, much of this development would not be economically viable if left to the market alone. Both large and small islands, however, have been severely destabilized by human efforts to 'freeze' the barrier islands with breakwaters, beach renourishment, and navigational dredging. While these techniques have managed to halt or disrupt natural processes along much of America's coasts, they have generally failed to conserve the barrier islands themselves: approximately 80% of America's barrier islands are eroding, at rates varying from 1 meter (3 feet) to 20 meters (65 feet) per year (Williams and Johnston, t995).
Coral Reefs
Among the most diverse ecosystems on Earth, coral reefs community are often likened to tropical rainforests. In U.S. waters, coral reefs are concentrated around the Florida Keys in warm waters (averaging 70 degrees Fahrenheit) that are also clear and shallow (under 200 feet deep), allowing sunlight to reach the living polyps that build the reef (Weber, et al, 1992). Reefs are rare in the areas of the Gulf open to OCS drilling, with an important exception: the Flower Garden Banks, the northern-most living coral reef on the North American continent. Sitting atop a salt dome in the middle of the Gulf, the Flower Garden Banks are isolated from smothering sediments coming of the mainland (Deslarzes, 1992). The Flower Garden Banks is home to at least 330 species, some of which have never been found anywhere else. Chemosynthetic ecosystems
Within just the last few years, oceanographers and marine biologists have discovered an entirely new and unexpected set of natural communities under the sea. The so-called 'chemosynthetic ecosystems' are, like land-based ecosystems, complex and elegant energy and food webs of micro- and macro-organisms. But, bizarrely, the bacteria at the base of these ecosystems, in the dark, piercingly cold depths of the ocean, apparently survive by consuming methane and hydrogen sulfide from frozen sea-floor deposits (MacDonald and Joye, 1997).

Specially-evolved 'ice worms' and mussels live there too, fed upon by eels and more familiar sea creatures. Scientists have barely begun to research these rare ecosystems, spread out in isolated but richly diverse patches on the continental shelf, and no estimate has yet been offered to suggest how human activities are affecting these systems. Most of the chemosynthetic ecosystems discovered to date, however, are in the sections of the Gulf in which OCS operations are being conducted, and are vulnerable to physical destruction during platform and pipeline construction and smothering by drill wastes.
The Need for Conservation
Coastal conservation efforts have been underway for decades, however, they have failed to address the significance of the threats in a systematic or comprehensive way. If properly crafted, S. 25, the "Conservation and Reinvestment Act of 1999," could help mitigate the damage to the environment that is created by offshore oil and gas development. It is entirely appropriate to reinvest revenues from the sale of non-renewable resources in the conservation of renewable resources such as land, wildlife, habitat, air and water. At the same time, it is critical that any legislation that is intended to meet these needs does not simultaneously create negative environmental impacts by encouraging more oil and gas development. 'Impact assistance funds' for coastal governments should be explicitly dedicated to environmentally sound projects and programs that include public input. Further, allocation of these funds should be structured so that local communities are not encouraged to support inappropriate oil and gas development along their coasts.
NWF recommends that coastal impact assistance funds distributed under Title I of S. 25 be designated for use by state and local governments to mitigate the environmental damage created by offshore development. The types of projects that we consider appropriate would include:
- amelioration of any adverse environmental impacts resulting from the siting, construction, expansion, or operation of OCS facilities;
- projects and activities, including habitat acquisition, that protect or enhance air quality, water quality, fish and wildlife, or wetlands in the coastal zone;
- administrative costs the state or local government incurs in approving or disapproving or permitting OCS development/production activities under any applicable law including the Coastal Zone Management Act and the OCS Lands Act; and/or
- the repurchase of OCS leases.
Because revenues for all three titles of the bill would come from existing and new leases, and the allocation formula in Title I ties 50% of a state or local government's allocation directly to proximity to OCS production, states and local governments are likely to support new leasing as well as development on existing leases to increase the amount of money available to them. The legislation should be amended to exclude new leasing revenues or revenues received from production in areas that are currently subject to leasing moratoria. In addition, if the allocation formula to states and local governments is based on proximity to OCS activity then it should include a flat, static percentage allocation based on past leasing and/or production. This would acknowledge states that have suffered OCS impacts to date without providing an incentive for new leasing exploration or production.
Oversight and accountability are critical to the success of an impact assistance program. Control and distribution of impact aid funds should reside with NOAA and/or EPA t not the Interior Department. NOAA and/or EPA should have the authority to review and approve in advance the annual plans proposed by each state and local government to ensure that the money will be used for the previously mentioned purposes, will not be inconsistent with the CZMA, CWA or other environmental statutes, will benefit the coastal environment of the state and are well-justified in terms of demonstrated need, design and proposed manner, and cost of implementation. NOAA and/or EPA should also be required to monitor implementation of the plans.
In addition, NWF commends the application of OCS dollars to two other conservation areas that have historically been underfunded -- the Land and Water Conservation Fund and state fish and wildlife programs. Just as NWF recommends that the coastal impact title of the bill be tightened to ensure that the dollars are directed to the greatest conservation need, we also recommend tightening the language regarding wildlife funding to ensure that it emphasizes non-game wildlife protection. Attached is a letter signed by NWF and other leading conservation organizations that outlines some of these suggestions and concerns in greater detail.
Our coastal and marine resources are critically important and severely threatened. As outlined by this testimony, NWF believes that offshore oil and gas drilling has, and will continue to be a major source of environmental degradation to these resources. Legislation that takes dollars generated from these activities and pours it into something positive would result in much-needed conservation actions for coastal and other natural resources.
If amended to address the concerns that we have outlined, S. 25 would constitute a lasting, historic contribution to the conservation cause.
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END


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