Document BR282ZroD5g2EGO8o7VoBbaow

The Office of the Assistant Secretary, Land and Minerals Management Action Plans Pursuant to Secretarial Orders regarding The Bureau of Land Management, The Bureau of Ocean Energy Management, The Bureau of Safety and Environmental Enforcement, and The Office of Surface Mining Reclamation and Enforcement SO 3417 - Addressing the National Energy Emergency ASLM Action Plans Pursuant to SO 3417 - Addressing the National Energy Emergency POLICY GOALS Bureau of Land Management (BLM) Reduce barriers to and burdens on domestic energy and minerals (including critical minerals) development Bureau of Ocean Energy Management (BOEM) Expedite identification, permitting, leasing, development, and production of domestic energy resources and critical minerals on the Outer Continental Shelf (OCS) Bureau of Safety and Environmental Enforcement (BSEE) (b) (5) Bureau of Land Management (BLM) Deliberative Discussion Draft (02/13/2025) Title: Assistant Secretary for Land and Minerals Management Action Plan for Secretary's Order 3417 - Addressing the National Energy Emergency Summary: Section 4(a) of SO 3417 requires all bureaus to identify the emergency authorities available to them, as well as all other legal authorities, to facilitate the identification, permitting, leasing, development, production, transportation, refining, distribution, exporting, and generation of domestic energy resources and critical minerals. Section 4(b) of SO 3417 requires all bureaus to identify all relevant emergency and other legal authorities available to them to expedite the completion of all authorized and appropriate infrastructure, energy, environmental, and natural resources projects within their jurisdiction to perform or to advance, including use of all authorities to facilitate the supplying, refining, transporting, and exporting of energy including, but not limited to, in and through the West Coast of the United States, the Northeast of the United States, and Alaska. Because of the overlap between the two Sections, the Bureau's work on them will be consolidated into one effort. The Bureau is working with the Office of the Solicitor (SOL) on implementation of SO 3417. Top priorities: (b) (5) Additional Information: None. Bureau of Ocean Energy Management (BOEM) ATTACHMENT 1: SO 3417 - BOEM Emergency Authorities - Review and Recommendations SO 3417 - Addressing the National Energy Emergency Listed below are key statutes where emergency authority exists in some form and important notes or actions. Legislation containing emergency authority ESA 50 CFR 402.05 - Emergencies (a) Where emergency circumstances mandate the need to consult in an expedited manner, consultation may be conducted informally through alternative procedures that the Director determines to be consistent with the requirements of sections 7(a)-(d) of the Act. This provision applies to situations involving acts of God, disasters, casualties, national defense or security emergencies, etc. (b) Formal consultation shall be initiated as soon as practicable after the emergency is under control. The Federal agency shall submit information on the nature of the emergency action(s), the justification for the expedited consultation, and the impacts to endangered or threatened species and their habitats. The Service will evaluate such information and issue a biological opinion including the information and recommendations given during the emergency consultation. Does BOEM have discretion to apply this authority? If not BOEM, then who? Any actions to take? (b) (5) NEPA - 40 CFR 1506.11 Where emergency circumstances make it necessary to take an action with significant effects without observing the provisions of the regulations in this subchapter, the Federal agency taking the action shall consult with the Council about alternative arrangements for compliance with section 102(2)(C) of NEPA. Agencies and the Council shall limit such arrangements to actions necessary to control the immediate impacts of the emergency; other actions remain subject to NEPA review consistent with this subchapter. Alternative arrangements do not waive the requirement to comply with the statute but establish an alternative means for NEPA compliance. (b) (5) NHPA/Sec 106 - 36 CFR 800.12 (b) Alternatives to agency procedures. In the event an agency official proposes an emergency undertaking as an essential and immediate response to a disaster or emergency declared by the President, a tribal government, or the Governor of a State or another immediate threat to life or property, and the agency has not developed procedures pursuant to paragraph (a) of this section, the agency official may comply with section 106 by: (1) Following a programmatic agreement developed pursuant to S 800.14(b) that contains specific provisions for dealing with historic properties in emergency situations; or (2) Notifying the Council, the appropriate SHPO/THPO and any Indian tribe or Native Hawaiian organization that may attach religious and cultural significance to historic properties likely to be affected prior to the undertaking and affording them an opportunity to comment within seven days of notification. If the agency official determines that circumstances do not permit seven days for comment, the agency official shall notify the Council, the SHPO/THPO and the Indian tribe or Native Hawaiian organization and invite any comments within the time available. ... (d) Applicability. This section applies only to undertakings that will be implemented within 30 days after the disaster or emergency has been formally declared by the appropriate authority. An agency may request an extension of the period of applicability from the Council prior to the expiration of the 30 days. Immediate rescue and salvage operations conducted to preserve life or property are exempt from the provisions of section 106 and this part. OCSLA - 43 USC 1341(c), but only for suspending operations on leases. All leases issued under this subchapter, and leases, the maintenance and operation of which are authorized under this subchapter, shall contain or be construed to contain a provision whereby authority is vested in the Secretary, upon a recommendation of the Secretary of Defense, during a state of war or national emergency declared by the Congress or the President of the United States after August 7, 1953, to suspend operations under any lease; and all such leases shall contain or be construed to contain provisions for the payment of just compensation to the lessee whose operations are thus suspended. CAA - 42 USC 7410(f): State Implementation Plans (b) (5) (b) (5) The below statutes were reviewed in addition to those listed in the table above. CZMA - Coastal Zone Management Act: 16 U.S.C. 1451 et seq. OPA - Oil Pollution Act: 33 U.S.C. Chapter 40 GOMESA - Gulf of Mexico Energy Security Act: Public Law 109-432 NMSA - National Marine Sanctuary Act: 16 U.S.C. 1431 et seq. MSFCMA - Magnuson-Stevens Fishery Conservation and Management Act: 16 U.S.C. 1801 et seq. MBTA - Migratory Bird Treaty Act: 16 U.S.C. 703-712 MMPA - Marine Mammal Protection Act: 16 U.S.C. 1361-1407 CWA - Clean Water Act: 33 U.S.C. 1251 et seq. CAA - Clean Air Act: 42 U.S.C. Chapter 85 There are no emergency authorities under the CZMA, OPA, GOMESA, NMSA, MSFCMA, MBTA, and MMPA. Under the CWA, the Administrator of the EPA has emergency powers, but is only applicable to restraining any person discharging pollutants and they are not applicable to SO 3417. List of acronyms: ESA - Endangered Species Act NEPA - National Environmental Policy Act NHPA - National Historical Preservation Act OCSLA - Outer Continental Shelf Lands Act Bureau of Safety and Environmental Enforcement (BSEE) United States Department of the Interior BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT WASHINGTON, DC 20240-0001 Memorandum February 13, 2025 To: Cara Lee Macdonald Chief of Staff, Exercising the Delegated Authorities of the Assistant Secretary, Land and Minerals Management From: Paul P. Huang Acting Director Bureau of Safety and Environmental Enforcement Subject: Action Plan to Implement Secretarial Order 3417 - Addressing the National Energy Emergency Summary In accordance with Secretarial Order (S.O.) 3417 - Addressing the National Energy Emergency issued by Secretary Burgum on February 3, 2025, BSEE prepared the following action plan to ensure the efficient and timely implementation of President Trump's January 20, 2025, Executive Order (EO) 14156, titled "Declaring a National Energy Emergency." A cross-bureau team reviewed all agency actions subject to the directives in Section 4 of S.O. 3417 to create an action plan that identifies all relevant legal authorities, including emergency authorities, available to expedite all authorized processes associated with energy development within BSEE's jurisdiction on the federal Outer Continental Shelf (OCS), nationwide. Top Priorities In order to ensure efficiency and accountability in all BSEE-specific actions related to the approval of OCS operations, we recommend the following priorities for S.O. 3417 Section 4 implementation: (b) (5) 1 (b) (5) Additional Information (b) (5) 2 (b) (5) We stand ready to support the requests for more information on this strategy, including the approval of the included priority goals and associated action plan. Please let me or BSEE's Chief of Staff, Wes James (Weston.James@bsee.gov) know if you have any questions. cc: Acting Director, BOEM 3 (b) (5) 5 (b) (5) 7 (b) (5) 10 SO 3418 - Unleashing American Energy ASLM Action Plans Pursuant to SO 3418 - Unleashing American Energy POLICY GOALS Bureau of Land Management (BLM) (b) (5) Bureau of Ocean Energy Management (BOEM) (b) (5) Bureau of Safety and Environmental Enforcement (BSEE) (b) (5) Office of Surface Mining Reclamation and Enforcement (OSMRE) (b) (5) Bureau of Land Management (BLM) Deliberative Discussion Draft (02/13/2025) Title: Assistant Secretary for Land and Minerals Management Action Plan for Secretary's Order 3418 - Unleashing American Energy Summary: Section 4(b) of SO 3418 requires the Assistant Secretary for Land and Minerals Management (ASLM) to develop an action plan describing the steps that will be taken to "suspend, revise, or rescind" certain decisions, including several Bureau of Land Management (BLM) regulations, Instruction Memoranda (IM), and planning decisions. Actions to be taken by the BLM are described below. Tables are provided for each of the BLM's top priorities. (b) (5) Section 4(c) of SO 3418 requires the ASLM to develop an action plan describing the steps to be taken that would accomplish other Department priority actions, including reducing barriers to the use of Federal lands for energy development and removing undue burdens on domestic mining and processing of nonfuel minerals. Top priorities: (b) (5) 1 Deliberative Discussion Draft (02/13/2025) Title: Assistant Secretary for Land and Minerals Management Action Plan for Secretary's Order 3418 - Unleashing American Energy Additional Information: The following actions will reduce barriers to the use of Federal lands for energy development, consistent with the BLM's mission of managing public lands for multiple use and sustained yield, Congressional oversight, and Department authorities specific to Alaska. (b) (5) BLM and National Park Service (NPS) leadership will review the final NPS rule published in the Federal Register on December 5, 2024, entitled "Rights of Way" to evaluate impacts on access for exploration and development, particularly in Alaska; assess resulting costs; and submit those findings to the Office of Information and Regulatory Affairs (OIRA) for a "major rule" determination under 5 U.S.C. 804(2). Upon review and concurrence from BLM leadership on the specific actions listed below, the BLM will prepare a plan of action and milestones for these actions as appropriate: (b) (5) 2 Deliberative Discussion Draft (02/13/2025) Title: Assistant Secretary for Land and Minerals Management Action Plan for Secretary's Order 3418 - Unleashing American Energy (b) (5) 3 Deliberative Discussion Draft (02/13/2025) Title: Assistant Secretary for Land and Minerals Management Action Plan for Secretary's Order 3418 - Unleashing American Energy (b) (5) 4 Deliberative Discussion Draft (02/13/2025) Title: Assistant Secretary for Land and Minerals Management Action Plan for Secretary's Order 3418 - Unleashing American Energy Increase domestic energy production. 181 et seq.); 43 C.F.R. Parts 3100, 3200 Mineral Leasing Act of 1920, as amended (30 U.S.C. 181 et seq.); 43 C.F.R. Parts 3100, 3200 (b) (5) Increase domestic energy production. Mineral Leasing Act of 1920, as amended (30 U.S.C. 181 et seq.); 43 C.F.R. Parts 3100, 3200 10 Deliberative Discussion Draft (02/13/2025) Title: Assistant Secretary for Land and Minerals Management Action Plan for Secretary's Order 3418 - Unleashing American Energy (b) (5) ofdomestic energy. Eliminate undue burdens on development of domestic energy. NHPA and implementing regulations 26 Bureau of Ocean Energy Management (BOEM) (b) (5) 4b.NP.2 Accelerated execution of up to three lease sales in the Gulf of America region, beginning with Lease Sale 262. (b) (5) (b) (5) (b) (5) SO 3418 Attachments: Attachment 1: SO3418-Attachment 1-RevokedEO-Terminated Actions.docx Attachment 2: SO3418-Attachment2-BiOp Write Up.docx Attachment 3: SO3418-Attachment3-High-Level Summary for National OCS Program-related actions in response to Secretarial Order 3418 Attachment 4: SO3418 - Attachment4- Draft Project Schedule for 11th National Program Attachment 5: SO3418-Attachment5-NHPA Section 106 Review Summary Attachment 6: SO3418-Attachment6-Critical Minerals Barrier Analysis and Mapping Attachment 1 (b) (5) Attachment 1 (b) (5) Attachment 1 (b) (5) Attachment 1 (b) (5) To: Cara Lee Macdonald Chief of Staff, exercising the delegated authority of the Assistant Secretary, Land and Minerals Management From: Walter Cruickshank, Ph.D. Acting Director, BOEM Subject: SO 3418 - BOEM suggested actions to suspend, revise or rescind the "Biological Opinion on the Federally Regulated Oil and Gas program Activities in the Gulf of Mexico" (March 13, 2020) and Incidental Take Statement (April 24, 2021) Informational Memo Section 4(b) of SO 3418 directs a review of and action to suspend, revise, or rescind the "Biological Opinion on the Federally Regulated Oil and Gas Program Activities in the Gulf of Mexico" (March 13, 2020; 2020 BiOp) and the associated "Revised Incidental Take Statement and Revised Appendices A, C, D, and I" (April 24, 2021). (b) (5) Potential Action: (b) (5) Attachment 2 To: Cara Lee Macdonald Chief of Staff, exercising the delegated authority of the Assistant Secretary, Land and Minerals Management From: Walter Cruickshank, Ph.D. Acting Director, BOEM Subject: High-Level Summary for National OCS Program-related actions in response to Secretarial Order 3418, Unleashing American Energy Informational Memo DOI Action Plan Inputs: BOEM Draft Action Plan items regarding OCS oil and gas leasing As part of the Departmental action plan to implement Secretarial Order 3418, BOEM is prepared to simultaneously: 1. revise the current, 2024-2029 National Outer Continental Shelf (OCS) Oil and Gas Leasing Program (National OCS Program) by considering options to accelerate the three Gulf of America (GOA) lease sales, and 2. initiate the development of a new National OCS Program to follow on or replace the current, 2024-2029 Program as soon as practicable so as to allow for consideration of additional lease sales. BOEM has developed budget estimates for FY 2025 and FY 2026 to support the expedited development of a new (11th) National OCS Program and has developed a tentative schedule that would allow for 11th National OCS Program approval in roughly(b) (5) . (b) (5) Attachment 3 Background on Presidential and Secretarial Directives Executive Order (EO) 14154, titled Unleashing American Energy, states that it is the policy of the United States "to encourage energy exploration and production on Federal lands and waters, including on the Outer Continental Shelf, in order to meet the needs of our citizens and solidify the United States as a global energy leader long into the future..." and directs all agencies to..."develop and begin implementing action plans to suspend, revise, or rescind all agency actions identified as unduly burdensome under subsection (a) of this section, as expeditiously as possible and consistent with applicable law." Secretarial Order (SO) 3418 directs DOI Assistant Secretaries to promptly review all agency actions and submit an action plan to [the Secretary] in 15 days to consider how to comply with the policies outlined in EO 14154 and SO 3418. The plan required by SO 3418 is to include steps that will be taken to suspend, revise, or rescind various documents, including the Proposed Final Program, 2024-2029 National Outer Continental Shelf Oil and Gas Leasing 5-Year Plan (September 29, 2023). (emphasis added) In addition to the review described in subparagraph (a) and (b) above, all Assistant Secretaries are hereby directed to include in their action plans the steps to be taken to, among other things, "review the 5-year program for offshore oil and gas leasing to assess the need for changes to meet the Nation's energy goals, consistent with the principles outlined in the Outer Continental Shelf Lands Act (43 U.S.C. 1331 et seq.)." (emphasis added) Attachment 3 (b) Draft Project Schedule for the 11th National OCS Program (5) Deliberative, Pre-Decisional, For Internal Use Only, Do Not Distribute Last Updated: 12 February 2025 Key Points Draft Project Schedule for the 11th National OCS Program (b) (5) K i S Deliberative, Pre-Decisional, For Internal Use Only, Do Not Distribute Last Updated: 12 February 2025 To: Cara Lee Macdonald Chief of Staff, exercising the delegated authority of the Assistant Secretary, Land and Minerals Management From: Walter Cruickshank, Ph.D. Acting Director, BOEM Subject: Summary of BOEM's review of relevant regulations, policy and guidance to insure the lawful implementation of Section 106 of the National Historic Preservation Act" (NHPA) Informational Memo DOI Secretarial Order 3418: Unleashing American Energy Section 4c. instructs bureaus to take "... actions to review all relevant internal regulations, policies, and guidance to ensure the lawful implementation of section 106 of the National Historic Preservation Act" (NHPA). The below table lays out the regulations, policy, and guidance reviewed by BOEM and provides a summary of whether BOEM determined each item represents a lawful implementation of Section 106. Document Number Type Lawful Implementation of Section 106 (b) (5) Attachment 5 (b) (5) (b) (5) Attachment 5 To: Cara Lee Macdonald Chief of Staff, exercising the delegated authority of the Assistant Secretary, Land and Minerals Management From: Walter Cruickshank, Ph.D. Acting Director, BOEM Subject: BOEM High Level Summary - Action Plan Related to Secretarial Order 3418 Unleashing American Energy Informational Memo This document presents BOEM's initial action plan required by Section 4(c) regarding (1) potential actions reduce undue barriers and burdens on domestic mining and processing of marine minerals (including critical minerals), (2) actions that would accelerate the ongoing, detailed geologic mapping of the U.S., with a focus on locating previously unknown deposits of OCS critical minerals. 1. Reducing Undue Barriers and Burdens (b) (5) Attachment 6 Bureau of Safety and Environmental Enforcement (BSEE) United States Department of the Interior BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT WASHINGTON, DC 20240-0001 February 13, 2025 Memorandum To: Cara Lee Macdonald Chief of Staff, Exercising the Delegated Authorities of the Assistant Secretary, Land and Minerals Management From: Paul P. Huang Acting Director Bureau of Safety and Environmental Enforcement Subject: Action Plan for Secretarial Order 3418 - Unleashing American Energy In accordance with Secretarial Order 3418 - Unleashing American Energy, issued by Secretary Burgum on February 3, 2025, the Bureau of Safety and Environmental Enforcement (BSEE) has prepared the following action plan to support the United States' capacity to provide affordable and reliable energy according to President Trump's January 20, 2025, Executive Order 14154 also titled Unleashing American Energy. A cross-bureau team reviewed all agency actions subject to the directives in Section 4 of Secretary's Order 3418 to create an action plan that is both pursuable within BSEE's authorities and consistent with Executive Order 14154 priorities. Top Priorities (b) (5) Additional Information The additional information below provides context for actions in the BSEE action plan related to the "Biological Opinion on the Federally Regulated Oil and Gas Program Activities in the Gulf of Mexico" (March 13, 2020; 2020 BiOp) and the associated "Revised Incidental Take Statement and Revised Appendices A, C, D, and I" (April 24, 2021) as well as pending litigation. BSEE is also proposing innovative actions to improve energy and critical minerals permitting, development, and production. These additional actions require coordination with other federal and state agencies to evaluate their potential and to develop their implementation strategy. 1 (b) (5) 2 (b) (5) We stand ready to support the requests for more information on this action plan, including the approval of the above recommendations. Please let me or BSEE's Chief of Staff, Wes James (Weston.James@bsee.gov) know if you have any questions. cc: Acting Director, BOEM 3 Office of Surface Mining Reclamation and Enforcement (OSMRE) Title: Assistant Secretary for Land and Minerals Management Action Plan for SO 3418 - Unleashing American Energy Summary: Provide summary of action plan to accomplish the policy goals for this SO. Top priorities: List up to the top 5 priorities for this SO and provide justification for each recommendation. Additional Information: Provide any other additional information that needs to be considered to successfully implement this action plan. 1 (b) (5) 3 (b) (5) 6 (b) (5) 8 SO 3419 - Delivering Emergency Price Relief for American Families and Defeating the Cost-of-Living Crisis ASLM Action Plans Pursuant to SO 3419 - Delivering Emergency Price Relief for American Families and Defeating the Cost-of-Living Crisis POLICY GOALS Bureau of Land Management (BLM) Identify regulations, programs, and processes that may increase costs for the American people and take steps to lower costs Bureau of Ocean Energy Management (BOEM) Identify "climate" policies that increase the cost of food or energy Bureau of Safety and Environmental Enforcement (BSEE) Ensuring that BSEE promptly identifies appropriate actions to cut red tape that will reduce costs for Americans O ice of Surface Mining Reclamation and Enforcement (OSMRE) Create employment opportunities for American workers, including drawing discouraged workers into the labor force and reduce labor underutilization Expedite authorization for Abandoned Mine Lands (AML) construction projects to support the labor force and reduce labor underutilization Bureau of Land Management (BLM) Deliberative Discussion Draft (02/13/2025) Title: Assistant Secretary for Land and Minerals Management for Secretary's Order 3419 - Delivering Emergency Price Relief for American Families and Defeating the Cost-of-Living Crisis Summary: Section 4 of Secretary's Order (SO) 3419 requires all bureaus and offices to conduct a review of programs and regulations to identify any that may cause higher costs for Americans, with a particular focus on policies that raise the cost of food or energy. The review shall also address employment opportunities for American workers. Section 5(b) of the SO also requires all bureaus and offices to report the results of the review required in Section 4 and complete implementation actions, including modifications to policies, procedures, or practices that are inconsistent with the January 20, 2025, Presidential Memorandum titled "Delivering Emergency Price Relief for American Families and Defeating the Cost-of-Living Crisis" (Cost-ofLiving Memo), which requires that the Department of the Interior (DOI) promptly identify appropriate actions to cut red tape that will reduce costs for Americans. Top priorities: (b) (5) 1 Deliberative Discussion Draft (02/13/2025) Title: Assistant Secretary for Land and Minerals Management for Secretary's Order 3419 - Delivering Emergency Price Relief for American Families and Defeating the Cost-of-Living Crisis (b) (5) Additional Information:(b) (5) 2 Bureau of Ocean Energy Management (BOEM) To: Charlie Dankert Acting Assistant Secretary, Policy, Management, and Budget From: Walter Cruickshank, Ph.D. Acting Director, BOEM Subject: BOEM Analysis of SO 3419 - Delivering Emergency Price Relief for American Families and Defeating the Cost-of-Living Crisis Informational Memo Secretarial Order 3419 directs agencies to consider any "policies and decisions that directly or indirectly increase costs" and to "particularly focus on coercive `climate' policies that increase the cost of food or energy." Because the oil market is global, the policies and regulations of any one country are unlikely to lead to changes in global oil prices. However, policies and regulations can impact producers at the margin, potentially making some prospects uneconomic or possibly incentivizing companies to move to more economically attractive basins. After reviewing recent policies, BOEM identified (b) (5) Bureau of Safety and Environmental Enforcement (BSEE) United States Department of the Interior BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT WASHINGTON, DC 20240-0001 Memorandum February 13, 2025 To: Cara Lee Macdonald Chief of Staff, Exercising the Delegated Authorities of the Assistant Secretary, Land and Minerals Management From: Paul P. Huang Acting Director Bureau of Safety and Environmental Enforcement Subject: Action Plan to Implement Secretarial Order 3419 - Delivering Emergency Price Relief for American Families and Defeating the Cost-of-Living Crisis Summary In accordance with Secretarial Order (SO) 3419, "Delivering Emergency Price Relief for American Families and Defeating the Cost-of-Living Crisis," issued by Secretary Burgum on February 3, 2025, the Bureau of Safety and Environmental Enforcement (BSEE) prepared the following action plan to ensure the efficient and timely implementation of the January 20, 2025, Presidential Memorandum on "Delivering Emergency Price Relief for American Families and Defeating the Cost-of-Living Crisis," (Cost-of-Living Memo). A cross-bureau team reviewed all agency actions subject to the directives in Section 4 of SO 3419 to create an action plan pursuable within BSEE's authorities and consistent with the Cost-of-Living Memo. Top Priorities Review programs and regulations. Consistent with the BSEE review for SO 3418, "Unleashing American Energy," review BSEE programs and regulations to consider potential direct or indirect increased cost for energy. Additional Information (b) (5) DRAFT//DELIBERATIVE (b) (5) We stand ready to support the requests for more information on this strategy, including the approval of the included priority goal and recommendations. Please let me or BSEE's Chief of Staff, Wes James (Weston.James@bsee.gov) know if you have any questions. cc: Acting Director, BOEM DRAFT//DELIBERATIVE - 2 Office of Surface Mining Reclamation and Enforcement (OSMRE) Title: Assistant Secretary for Land and Minerals Management Action Plan for SO 3419 - Delivering Emergency Price Relief for American Families and Defeating the Cost-of-Living Crisis Summary: Provide summary of action plan to accomplish the policy goals for this SO. Top priorities: List up to the top 5 priorities for this SO and provide justification for each recommendation. Additional Information: Provide any other additional information that needs to be considered to successfully implement this action plan. 1 (b) (5) 3 (b) (5) 5 SO 3420 - Announcing President Trump's Revocation of Former Outer Continental Shelf Withdrawals ASLM Action Plans Pursuant to SO 3420 - Announcing President Trump's Revocation of Former Outer Continental Shelf Withdrawals ACTION ITEMS Bureau of Safety and Environmental Enforcement (BSEE) (b) (5) Bureau of Safety and Environmental Enforcement (BSEE) United States Department of the Interior BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT WASHINGTON, DC 20240-0001 Memorandum February 13, 2025 To: Cara Lee Macdonald Chief of Staff, Exercising the Delegated Authorities of the Assistant Secretary, Land and Minerals Management From: Paul P. Huang Acting Director Bureau of Safety and Environmental Enforcement Subject: Strategy to Implement Secretarial Order 3420, "Announcing President Trump's Revocation of Former Outer Continental Shelf Withdrawals" As our bureau continues to advance safety and environmental protection related to energy development on the U.S. Outer Continental Shelf (OCS), BSEE will ensure the efficient and timely implementation of President Trump's January 20, 2025, Executive Order (EO), "Initial Rescissions of Harmful Executive Orders and Actions." In accordance with Secretarial Order (SO) 3420, "Announcing President Trump's Revocation of Former Outer Continental Shelf Withdrawals," issued by Secretary Burgum on February 3, 2025, BSEE will implement the following steps: (b) (5) Our bureau remains committed to maintaining the safe, reliable, and diversified supply of energy for our Nation. We stand ready to support the requests for more information on this strategy, including the approval of the above recommendations. Please let me or BSEE's Chief of Staff, Wes James (Weston.James@bsee.gov), know if you have any questions. cc: Acting Director, BOEM SO 3421 - Achieving Prosperity through Deregulation ASLM Action Plans Pursuant to SO 3421 - Achieving Prosperity through Deregulation ACTION ITEMS Bureau of Safety and Environmental Enforcement (BSEE) Pause current regulatory activity to await the updated guidance--consistent with the SO and corresponding EO--from the Office of Management and Budget (OMB) and the DOI Office of the Executive Secretariat and Regulatory Affairs (OES) Once guidance is received, ensure timely documentation of our bureau's steps for ensuring consistent application of this guidance to any BSEE regulatory action Bureau of Safety and Environmental Enforcement (BSEE) United States Department of the Interior BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT WASHINGTON, DC 20240-0001 Memorandum February 13, 2025 To: Cara Lee Macdonald Chief of Staff, Exercising the Delegated Authorities of the Assistant Secretary, Land and Minerals Management From: Paul P. Huang Acting Director Bureau of Safety and Environmental Enforcement Subject: Strategy to Implement Secretarial Order 3420, "Announcing President Trump's Revocation of Former Outer Continental Shelf Withdrawals" As our bureau continues to advance safety and environmental protection related to energy development on the U.S. Outer Continental Shelf (OCS), BSEE will ensure the efficient and timely implementation of President Trump's January 20, 2025, Executive Order (EO), "Initial Rescissions of Harmful Executive Orders and Actions." In accordance with Secretarial Order (SO) 3420, "Announcing President Trump's Revocation of Former Outer Continental Shelf Withdrawals," issued by Secretary Burgum on February 3, 2025, BSEE will implement the following steps: (b) (5) Our bureau remains committed to maintaining the safe, reliable, and diversified supply of energy for our Nation. We stand ready to support the requests for more information on this strategy, including the approval of the above recommendations. Please let me or BSEE's Chief of Staff, Wes James (Weston.James@bsee.gov), know if you have any questions. cc: Acting Director, BOEM ASLM Action Plans Pursuant to SO 3421 - Achieving Prosperity through Deregulation ACTION ITEMS Bureau of Safety and Environmental Enforcement (BSEE) Pause current regulatory activity to await the updated guidance--consistent with the SO and corresponding EO--from the Office of Management and Budget (OMB) and the DOI Office of the Executive Secretariat and Regulatory Affairs (OES) Once guidance is received, ensure timely documentation of our bureau's steps for ensuring consistent application of this guidance to any BSEE regulatory action Bureau of Safety and Environmental Enforcement (BSEE) United States Department of the Interior BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT WASHINGTON, DC 20240-0001 Memorandum February 13, 2025 To: Cara Lee Macdonald Chief of Staff, Exercising the Delegated Authorities of the Assistant Secretary, Land and Minerals Management From: Paul P. Huang Acting Director Bureau of Safety and Environmental Enforcement Subject: Strategy to Implement Secretarial Order 3421, "Achieving Prosperity through Deregulation" As our bureau continues to advance safety and environmental protection related to energy development on the U.S. Outer Continental Shelf (OCS), it is imperative that our organization ensure the efficient and timely implementation of President Trump's January 20, 2025, Executive Order (EO), "Unleashing Prosperity Through Deregulation." In accordance with the Secretarial Order (SO) 3421, "Achieving Prosperity through Deregulation," issued by Secretary Burgum on February 3, 2025, BSEE will communicate the contents of SO 3421 to bureau staff. BSEE also recognizes the importance of consistency with any updated guidance from the Office of Management and Budget (OMB) and the DOI Office of the Executive Secretariat and Regulatory Affairs (OES) that will provide consistency with the EO and SO. As such, BSEE will pause current regulatory activity to await the respective OMB and OES guidance. Once received, BSEE will ensure timely documentation of our bureau's steps for ensuring consistent application of this guidance to any BSEE regulatory action. Our bureau remains committed to ensuring the safe, reliable, and diversified supply of energy for our Nation. We stand ready to support the requests for more information on this strategy, including the approval of the above recommendations. Please let me or BSEE's Chief of Staff, Wes James (Weston.James@bsee.gov), know if you have any questions. cc: Acting Director, BOEM SO 3422 - Unleashing Alaska's Extraordinary Resource Potential ASLM Action Plans Pursuant to SO 3422 - Unleashing Alaska's Extraordinary Resource Potential POLICY GOALS Bureau of Land Management (BLM) (b) (5) Bureau of Safety and Environmental Enforcement (BSEE) (b) (5) Bureau of Land Management (BLM) Deliberative Discussion Draft Attorney-Client/Attorney Work Product Assistant Secretary for Land and Minerals Management Action Plan for SO 3422 - Unleashing Alaska's Extraordinary Resource Potential (EO 14153 Secs. 3(b)(vii), (viii) and (xvii-xviii) Summary: In response to Secretary's Order 3422, this draft action plan identifies options to implement provisions from Executive Order (EO) 14153, including Sec. 3(b)(vii) directing the BLM to evaluate changes to, including the potential recission of Public Land Order 5150, and any subsequent amendments, modifications, or corrections to it; Sec. 3(b)(viii) directing the BLM to review the 2024 Ambler Road Final Supplemental EIS (SEIS), analyze any deficiencies, and reinstate the 2020 ROD; and (xvii-xviii) directing the BLM to rescind the Central Yukon Record of Decision (ROD) and approved Resource Management Plan (RMP) signed on November 12, 2024 and reimplement the Central Yukon Draft RMP/EIS dated December 11, 2020. Top priorities: (b) (5) Additional Information: EO 14153 Section 3(b)(vii) directs the evaluation of changes to, including partial or full revocation of PLO 5150, which reserved approximately 5.3 million acres of Federal land in Alaska for the purpose of supporting a utility and transportation corridor in the aid of programs for the U.S. Government and the State of Alaska (36 Fed. Reg. 25,410 (December 31, 1971)) under authorities granted in the Alaska Native Claims Settlement Act (ANCSA), section 17(c). This corridor runs from Prudhoe Bay at the north end of the State to the port of Valdez in southcentral Alaska. Many of the Federal lands withdrawn by PLO 5150 are subject to other withdrawals, including ANCSA 17(d)(1) withdrawals. Any decision to revoke PLO 5150 would need to consider the application of public land laws through overlapping withdrawals. (b) (5) Deliberative Discussion Draft Attorney-Client/Attorney Work Product Assistant Secretary for Land and Minerals Management Action Plan for SO 3422 - Unleashing Alaska's Extraordinary Resource Potential (EO 14153 Secs. 3(b)(vii), (viii) and (xvii-xviii) (b) (5) Deliberative Discussion Draft Attorney-Client/Attorney Work Product Assistant Secretary for Land and Minerals Management Action Plan for SO 3422 - Unleashing Alaska's Extraordinary Resource Potential (EO 14153 Secs. 3(b)(vii), (viii) and (xvii-xviii) (b) (5) Deliberative Discussion Draft Attorney-Client/Attorney Work Product Assistant Secretary for Land and Minerals Management Action Plan for SO 3422 - Unleashing Alaska's Extraordinary Resource Potential (EO 14153 Secs. 3(b)(vii), (viii) and (xvii-xviii) (b) (5) Deliberative Discussion Draft Attorney-Client/Attorney Work Product Assistant Secretary for Land and Minerals Management Action Plan for SO 3422 - Unleashing Alaska's Extraordinary Resource Potential (EO 14153 Secs. 3(b)(vii), (viii) and (xvii-xviii) (b) (5) Deliberative Discussion Draft Attorney-Client/Attorney Work Product Assistant Secretary for Land and Minerals Management Action Plan for SO 3422 - Unleashing Alaska's Extraordinary Resource Potential (EO 14153 Secs. 3(b)(vii), (viii) and (xvii-xviii) (b) (5) Deliberative Discussion Draft Attorney-Client/Attorney Work Product Title: Assistant Secretary for Land and Minerals Management Action Plan for SO 3422 - Unleashing Alaska's Extraordinary Resource Potential (EO 14153 Secs. 3(b)(xv)(xvi)) Summary: This plan addresses the following provisions of section 3(b)(xv)-(xvi) of EO 14153: (xv) reinstate the following Public Land Orders: Public Land Order 7899, signed by the Secretary of the Interior on January 11, 2021; Public Land Order 7900, signed by the Secretary of the Interior on January 16, 2021; Public Land Order 7901, signed by the Secretary of the Interior on January 16, 2021; Public Land Order 7902, signed by the Secretary of the Interior on January 16, 2021; Public Land Order 7903, signed by the Secretary of the Interior on January 16, 2021; and any other such Public Land Order that the Secretary of the Interior determines would further the policy interests described in section 2 of EO 14153; and, (xvi) immediately review all Department of the Interior guidance regarding the taking of Alaska Native lands into trust and all Public Land Orders withdrawing lands for selection by Alaska Native Corporations to determine if any such agency action should be revoked to ensure the Department of the Interior's actions are consistent with the Alaska Statehood Act of 1958 (Public Law 85-508), the Alaska National Interest Lands Conservation Act (ANILCA) (16 U.S.C. 3101 et seq.), the Alaska Native Claims Settlement Act of 1971 (43 U.S.C. 1601, et seq.), the Alaska Land Transfer Acceleration Act (Public Law 108-452), and the Alaska Native Vietnam-era Veterans Land Allotment Program under section 1629g1 of title 43, United States Code. Top priorities: 1. Provide recommendations regarding Secretarial reinstatement or other action to address PLO Nos. 7899, 7900, 7901, 7902, and 7903, consistent with EO 14153 sec. 3(b)(xv); 2. Evaluate options and provide recommendations regarding any other withdrawals in Alaska for compliance with section 2 of EO 14153. Additional Information: Provide any other additional information that needs to be considered to successfully implement this action plan. Public Land Orders (PLOs) are a Secretarial-level decision; BLM will provide recommendations and follow Secretarial direction. Coordination with other federal agencies will be required to facilitate any changes to the withdrawals where lands are under their respective jurisdiction. The BLM can only make recommendations for BLM-managed lands and will defer to the agency's administrative processes for recommendations. (b) (5) Deliberative Discussion Draft Attorney-Client/Attorney Work Product Title: Assistant Secretary for Land and Minerals Management Action Plan for SO 3422 - Unleashing Alaska's Extraordinary Resource Potential (EO 14153 Secs. 3(b)(xv)(xvi)) (b) (5) 5 Deliberative Discussion Draft Attorney-Client/Attorney Work Product Title: Assistant Secretary for Land and Minerals Management Action Plan for SO 3422 - Unleashing Alaska's Extraordinary Resource Potential: Coastal Plain (EO 14153 Secs. 3(b)(i) - (b)(vi)) Summary: In response to Secretary's Order (SO) 3422, this draft action plan identifies options to implement direction in Executive Order (EO) 14153 concerning the Coastal Plain (1002 area) of Arctic National Wildlife Refuge (ANWR), as laid out in Sections 3(b)(i)-(vi). Top priorities: (b) (5) Additional Information: Sec. 3(b)(i) directed the Department to withdraw SO 3401 from June 2021, which has already been implemented by SO 3422. Sec. 3 (b)(ii) requires cancelled leases to be reissued and calls for additional leasing. (b) (5) Also relevant to Sec. 3(b)(ii), (b) (5) Secs. 3(b)(iii), (v), and (vi) direct rescission of the 2024 Final Supplemental Environmental Impact Statement (SEIS) and ROD, and reinstatement of the 2019 Final EIS and 2020 ROD. (b) (5) 1 Deliberative Discussion Draft Attorney-Client/Attorney Work Product Title: Assistant Secretary for Land and Minerals Management Action Plan for SO 3422 - Unleashing Alaska's Extraordinary Resource Potential: Coastal Plain (EO 14153 Secs. 3(b)(i) - (b)(vi)) (b) (5) 3 Assistant Secretary for Land and Minerals Management Action Plan for SO 3422 - Unleashing Alaska's Extraordinary Resource Potential: Alaska LNG and TAPS (EO 14153 Sections Sec. 3 (b) (ii) and Sec. 3 (xxiii)) Summary: In response to Secretary's Order (SO) 3422, this draft action plan addresses direction in EO 14153 to prioritize the development of Alaska's Liquified Natural Gas (LNG) potential (Sec. 2(d) and Sec. 3(b)(ii)) and to identify and assess the long-term viability of the Trans-Alaska Pipeline System (TAPS) and the associated Federal right-of-way (ROW) as an energy corridor of critical national importance (Sec. 3(b)(xxiii)). Top priorities: (b) (5) Additional Information: (b) (5) 1 Assistant Secretary for Land and Minerals Management Action Plan for SO 3422 - Unleashing Alaska's Extraordinary Resource Potential: Alaska LNG and TAPS (EO 14153 Sections Sec. 3 (b) (ii) and Sec. 3 (xxiii)) (b) (5) 3 Title: Assistant Secretary for Land and Minerals Management Action Plan for SO 3422 - Unleashing Alaska's Extraordinary Resource Potential: Navigability (EO 14153 Secs. 3(b)(xxi)) Summary: This draft action plan identifies options to implement direction in Secretary's Order (SO) 3422 and Executive Order (EO) 14153 (Section 3(b)(xxi)) to immediately conduct a navigability review of Alaska waters. Top Priorities: (b) (5) Additional Information: (b) (5) 1 Title: Assistant Secretary for Land and Minerals Management Action Plan for SO 3422 - Unleashing Alaska's Extraordinary Resource Potential: Navigability (EO 14153 Secs. 3(b)(xxi)) (b) (5) 3 Deliberative Discussion Draft Attorney-Client/Attorney Work Product Assistant Secretary for Land and Minerals Management Action Plan for SO 3422 - Unleashing Alaska's Extraordinary Resource Potential: National Petroleum Reserve in Alaska (EO 14153 Secs. 3(b)(ix-x, xii-xiv)) Summary: In response to Secretary's Order (SO) 3422, this draft action plan identifies options to implement direction in Executive Order (EO) 14153 concerning the National Petroleum Reserve in Alaska (NPR-A), as outlined in Sections 3(b)(ix)-(x) and 3(b)(xii)-(xiv). Top priorities: (b) (5) Additional Information: 3(b)(ix) and (xiii) direct rescission of the final rule entitled "Management and Protection of the National Petroleum Reserve in Alaska," 89 Fed. Reg. 38712 (May 7, 2024). (b) (5) . 3(b)(x) directs rescission of the January 16, 2025, guidance on protection of subsistence resource values in existing and proposed special areas and 3(b)(xiii) directs rescission of the notice entitled "Special Areas Within the National Petroleum Reserve in Alaska," 89 Fed. Reg. 58181 (July 17, 2024). (b) (5) 3(b)(xii) and (xiv) are principally oriented toward reverting to the 2020 Integrated Activity Plan (IAP) Record of Decision (ROD). (b) (5) 1 Deliberative Discussion Draft Attorney-Client/Attorney Work Product Assistant Secretary for Land and Minerals Management Action Plan for SO 3422 - Unleashing Alaska's Extraordinary Resource Potential: National Petroleum Reserve in Alaska (EO 14153 Secs. 3(b)(ix-x, xii-xiv)) (b) (5) 4 Bureau of Safety and Environmental Enforcement (BSEE) United States Department of the Interior BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT WASHINGTON, DC 20240-0001 Memorandum February 13, 2025 To: Cara Lee Macdonald Chief of Staff, Exercising the Delegated Authorities of the Assistant Secretary, Land and Minerals Management From: Paul P. Huang Acting Director Bureau of Safety and Environmental Enforcement Subject: Action Plan to Implement Secretarial Order 3422 - Unleashing Alaska's Extraordinary Resource Potential Summary In accordance with Secretarial Order (S.O.) 3422, "Unleashing Alaska's Extraordinary Resource Potential," issued by Secretary Burgum on February 3, 2025, BSEE prepared the following action plan to ensure the efficient and timely implementation of President Trump's January 20, 2025, Executive Order (E.O.) 14153, titled "Unleashing Alaska's Extraordinary Resource Potential." In accordance with S.O. 3422, BSEE will implement the following priority: Top Priorities Pursue rescission of previous Department of the Interior decision. As directed by Section 3(i) of E.O. 14153, BSEE's review of "any and all regulations, orders, guidance documents, policies, and any other similar agency actions that are inconsistent with the policy set forth in Section 2 of the" E.O., produced one agency decision which BSEE asserts may be within the scope of the E.O. and within the Department's authorities to rescind. Additional Information While E.O. 14153 and S.O. 3422 focus heavily on actions taken to unlock, prioritize and expedite development of resources located onshore Alaska, at least one "other similar agency action" under BSEE's jurisdiction over Alaska's Outer Continental Shelf (OCS) taken by the previous Acting Deputy Secretary of the Department of the Interior may be relevant to the orders. Combined with the President's January 20, 2025, E.O. titled "Initial Rescissions of Harmful Executive Order and Actions" which rescinds The Presidential Memorandum of March 13, 2023, titled "Withdrawal of Certain Areas off the United States Arctic Coast of the Outer Continental Shelf from Oil or Gas Leasing", there may be more than one path for BSEE to recommend attaining the President's goals specific to BSEE's jurisdiction. The action in question pertains to the Liberty Unit, an offshore oil development project in the Arctic OCS which has been previously approved for development twice over three decades but has been unable to proceed toward development for various investment and legal challenges. A decision to deny the lessee's request for a Suspension of Production for the three OCS leases which comprise the Liberty Unit, made by the former Acting Deputy Secretary of the Interior on December 26, 2024, resulted in the expiration of the three OCS leases and termination of the Unitization Agreement for the Liberty Unit. A briefing paper describing the issue in greater detail and including the relevant request and decision letter is attached. Action Plan (b) (5) Our bureau remains committed to ensuring the safe, reliable, and diversified supply of energy for our Nation. We stand ready to support the requests for more information on this strategy, including the approval of the above recommendations. Please let me or BSEE's Chief of Staff, Wes James (Weston.James@bsee.gov), know if you have any questions. Attachment(s): Issue Paper - Hilcorp (Feb 6, 2025) Liberty Lease Suspension Request Denial Hilcorp Response Letter for Liberty SOP BOEM Liberty DPP Review cc: Acting Director, BOEM BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT ISSUE: HILCORP ALASKA, LLC I. KEY POINTS (b) (5) II. OPPORTUNITIES AND CHALLENGES (b) (5) (b) (5) III. BACKGROUND (b) (5) IV. ATTACHMENTS Attachment 1 - Liberty Lease Suspension Request Denial Attachment 2 - Hilcorp Response Letter for Liberty SOP Attachment 3 - BOEM Liberty DPP Review V. PREPARED BY: Justin Miller, Alaska OCS Regional Director, Bureau of Safety and Environmental Enforcement DATE: February 6, 2025 Bureau of Ocean Energy Management Liberty DPP Request for Additional Information Item Number Document Page # Section 1 DPP 6 1.3 December 26, 2024 ENCLOSURE 1 Request for Additional Information Table 1-1 is missing information and/or contains inaccurate statements regarding requirements and consultations under the ESA and the MMPA. For example, the USFWS is listed as a regulatory agency but the National Marine Fisheries Service (NMFS) is not. Similar to the USFWS, NMFS also has responsibilities under both the ESA and the MMPA that are relevant to the proposed project. Additionally, there are multiple ESA-listed species that could be affected by the project but are not mentioned as requiring ESA consultations, including: spectacled eider, bowhead whale, ringed and bearded seals, and potentially others. Finally, several additional marine mammal species are found in the area and while not listed under the ESA, would still fall under the provisions of the MMPA. See 30 CFR 550.243(a) and 550.261(d) 2 DPP Include the schedule for all the proposed wells referenced in the DPP (e.g., how long the development and production phases could last if all wells are drilled). 13 2 - Schedule Specifically provide the schedule (year, hours per day, days per year) for drilling operations, workovers, or other maintenance activities for the wells. See 30 CFR 550.249, 30 CFR 550.257(b), 30 CFR 550.258(b), 30 CFR 550.241(a) 3 DPP Figure 3-9 Production Forecast appears to show the total production from the project over time in graphical form. Provide estimated projections of annual oil 23 Figure 3-9 (Bbl) and natural gas (mcf) production from the project in table form in order for BOEM to estimate annual GHG emissions and social costs in the NEPA analysis. Values should be provided for the project as a whole (all production wells) being considered under the plan. See 30 CFR 550.243(c)(1) 4 DPP 23-24 3.7 Hydrogen Sulfide Describe the H2S removal system on SDI and/or MPI: include Manufacturer, model, amine type and H2S waste disposal method, and the concentration of H2S in the waste stream of the amine unit. See 30 CFR 550.245(a) and 550.241(d) Page 1 of 8 Bureau of Ocean Energy Management Liberty DPP Request for Additional Information Item Number Document Page # Section 5 DPP 25 4 December 26, 2024 ENCLOSURE 1 Request for Additional Information In the DPP, describe pre-project vehicle traffic travelling to SDI and MPI. Describe the types and amounts of vehicle traffic increases expected from each stage of developing the Liberty Project (including ice road and gravel road trips) and for all phases of the project by season. Also include the vehicle traffic expected during normal production operations (e.g., after drilling and development activities). Include separate information for gravel road and ice road traffic. See 30 CFR 550.257(a), 550.257(c), and 550.261 6 DPP 26, 30 Table 5-1 & Table 5-3 Describe why in Table 5-3 for Corrosion Inhibitor the maximum produced water rate of 230,000 bbl/day is different than the Liberty Design Capacity of 55,000 bbl/day. See 30 CFR 550.243(d) 7 DPP In the DPP or WCCP Appendix E include the ice conditions, weather or other 5.7 Process constraints (e.g., environmental, open water season, etc.) where development 29 Safety Systems and production activities would be curtailed or not proceed. See 30 CFR 550.251(b) 8 DPP 32 Provide more information on the Doyon 26 and HAK's Innovation Rig, including heights and lighting regime. Large structures in this environment can pose a 6.1 hazard to birds, including listed species, and additional information is required to mitigate any potential adverse effects (e.g. lighting plan, boom management plan, etc.). See 30 CFR 550.254(b)(1), 30 CFR 550.261(c)(1) 9 DPP Include a brief description of the important safety and pollution prevention 34 Section 6.2 features of the Drilling Unit, including a table indicating the type and estimated Drilling Unit maximum quantity of fuels and oil stored on the facility. See 30 CFR 550.241(c) Page 2 of 8 Bureau of Ocean Energy Management Liberty DPP Request for Additional Information Item Number Document Page # Section 10 DPP 34 6.2 Drilling Unit December 26, 2024 ENCLOSURE 1 Request for Additional Information Provide the Doyon 26 rig specification sheet detailing the rig configuration to be used. Include information on the allocation of rig modules powered by main/highline power and those fueled independently by natural gas, diesel, or dual fuel. Rating values should be provided in HP for engines and MMBTU/HR for boilers, burners, or heaters. For engines, please indicate whether they are natural, diesel or dual fueled. Be sure to include emergency equipment along with an estimated duration of use. All this information should be entered into the BOEM-139 sheets, with emissions-producing equipment broken down by individual equipment type. Additional lines can be inserted as needed to account for all items. See 30 CFR 550.249 11 DPP 12 DPP 13 DPP 14 DPP 39-41 41 43-44 6.5 Logistics Provide locations of staging area and support sites for equipment, in addition to the SDI and MPI. Discuss supply/equipment staging or support areas in Deadhorse, and provide location and route to the SDI and MPI and estimated vehicle traffic. See 30 CFR 550.256(a) and 30 CFR 550.256(b), 30 CFR 550.258(a), 30 CFR 550 257 6.5 Logistics, Table 6-4 In this section (page 41) for the Mud Plant bullet, it states that "Both oil-based mud and water based mud systems and materials will be used." However in Table 6-4, Summary of Drilling Fluids for a Single Well, only water based and synthetic based muds are shown. Please specify if oil-based mud will be used and if so, include the chemical components in Table 6-4. See 30 CFR 550.243(b) and 550.243(d) Describe how the bulleted list of equipment that will be stored on the island 6.5 compares to what is there now (i.e., what is the increased level of activity (transportation, personnel, etc.). See 30 CFR 550.261(c)(1) 7.2 Support Facilities The plan states that only minor facility modifications are required at support facilities. Describe the modifications that will be done and the emissions associated with those modifications. See 30 CFR 550.249 Page 3 of 8 Bureau of Ocean Energy Management Liberty DPP Request for Additional Information Item Number Document Page # Section December 26, 2024 ENCLOSURE 1 Request for Additional Information 15 DPP 25, 43-44 4.5, 7.2 Provide a detailed map that includes all the Project-area roads/pads/activity areas referred to in these two sections. Note that the two text sections describe the bridges, causeway, breaches, etc. and other road-related facilities differently and a single map with complete labels is needed. Specify the location of all three gravel pads, and the location of the Badami tie-in pad. See 30 CFR 550.257(e) 16 DPP 17 DPP 51- 53 52 8.1.1.3 Provide copies of the Wildlife Interaction Plan, Master Wildlife Compliance Procedure, Avian Mortality Monitoring and Reporting guidance, and Bear Interaction, Mitigation, and Monitoring Plan as part of the plan and EIA. In addition, provide the specific monitoring and reporting measures to mitigate impacts to wildlife, ESA species, and marine mammals. Several of these plans are also referenced but not provided in the EIA. See 30 CFR 550.252(a), 30 CFR 550.254(a), 30 CFR550.261(c)(3) DPP 8.1.1.4 Identification of mitigation and monitoring is required for incidental take of ESA species. Provide additional information on potential spectacled eider take, including bird strikes. See 30 CFR 550.252(a) and 550.252(b)(1) 18 DPP Provide the current location of the drilling rig, transportation route to the SDI, type and number of truck trips to mobilize the drilling rig to SDI. See 30 CFR 550.256(a)(1) and 30 CFR 550.261 Page 4 of 8 Bureau of Ocean Energy Management Liberty DPP Request for Additional Information Item Number Document Page # Section December 26, 2024 ENCLOSURE 1 Request for Additional Information 19 DPP Include BOEM-0139 air emissions worksheets (https://www.boem.gov/boem0139) for the proposed DPP activities at SDI and MPI, as well as any support activities (e.g. ice road construction, waste hauling etc.) that are associated with this DPP. Identify and list all emission sources and their estimated emissions. These worksheets can be accessed on BOEM's Overview of Air Quality Regulations page found at https://www.boem.gov/environment/environmentalstudies/overview-air-quality-regulations . 8.3.1 Projected Detailed instructions for using these worksheets are provided in the BOEM-0139 54 Emissions Air Emissions Calculation Instructions found at https://www.boem.gov/boem- 0139-instructions . If your equipment is not listed, add its emissions factor to the factors page and cite your source (e.g., EPA, AP, or your engine specification sheet emissions factor). If you are using a unique engine factor, provide supporting information. For further background, refer to the 2011 Gulfwide Emission Inventory Study found at https://espis.boem.gov/final%20reports/5440.pdf . See 30 CFR 550.249, 30 CFR 550.257(b), 30 CFR 550.258(b) 20 DPP In the BOEM-139 air emissions worksheets outline which vehicles will be used for specific activities, including their counts, engine horsepower, estimated operational hours per day, and days per year: this applies to any process that 7.2.1 Gravel generates emissions associated with the DPP. For example, in ice road Roads and construction, provide a detailed breakdown of the counts, engine horsepower, 47 Pads 7.2.2 operational hours, and operational days for equipment such as articulated dump Ice Roads trucks, vacuum trucks, all-terrain vehicles, bulldozers, excavators, trimmers, hot water trucks, motor graders, auger equipment, and other support equipment. Additionally, include estimates for maintenance durations during the winter season. See 30 CFR 550.249, 30 CFR 550.257(b), 30 CFR 550.258(b) Page 5 of 8 Bureau of Ocean Energy Management Liberty DPP Request for Additional Information Item Number Document Page # Section 21 DPP Air December 26, 2024 ENCLOSURE 1 Request for Additional Information Break down the Fuel and Mud Storage equipment by individual equipment emissions sources, and location (e.g. SDI location, Rig Module or MPI). See 30 CFR 550.249 22 DPP Air Include estimates of any cold vent and potential fugitive emissions listed in the BOEM 139 sheets. See 30 CFR 550.249 23 DPP 24 DPP 25 DPP 26 DPP 55-57 55-57 55-58 Specify if the mud plant at the SDI will use highline power or an independent fuel source. If it uses an independent fuel source, specify the type of fuel, operational hours per day, and days per year. Specify if there is a mud plant at MPI, and if Air there is, include whether or not it has an independent power source. Additionally, specify if the onboard mud plant of Doyon Rig 26 will be utilized. If so, specify if it operates on main power or an independent power source, and the specific fuel source, if applicable. See 30 CFR 550.249 8.3.2 ERD Rig Emissions 8.3.3 Endicott Production Facility Emissions According to the plan, no portable flaring is anticipated; however Doyon Rig 26, SDI, and MDI have a flare, and emergency flaring emissions should be considered and estimated in the BOEM 139 sheets under the COMBUSTION FLARE line items. See 30 CFR 550.249(c) 8.3.2 ERD Rig Emissions 8.3.3 Endicott Production Facility Emissions 8.3.2 ERD Rig Emissions 8.3.3 Endicott Production Facility Emissions For rig and facility emissions tables, TSP, PM10, and PM2.5 are reported collectively as particulate matter rather than individually, as outlined in the BOEM139 air emissions worksheets. See 30 CFR 550.249 The emissions table are missing other pollutants found on BOEM 139 worksheets (e.g., Pb, NH3, etc.). See 30 CFR 550.249 Page 6 of 8 Bureau of Ocean Energy Management Liberty DPP Request for Additional Information Item Number Document Page # Section 27 DPP 56 Table 8-1 28 DPP 69 DPP 11.1 ; 3.16 (EIA) December 26, 2024 ENCLOSURE 1 Request for Additional Information Provide a breakdown of the Miscellaneous Support equipment by individual source. See 30 CFR 550.249 The DPP and EIA describes archaeological studies completed in the Foggy Island Bay area. Specify if these studies cover the area of the proposed ice road, and if any surveys of the ice road corridor are planned or have already been done. See 30 CFR 550.261(b)(6) Provide references and summarize information on the acoustic environment, especially information on ambient conditions and changes in the acoustic 29 EIA 28 3.6.4 environment during activities similar to those proposed. Provide supporting information and references for the DPP's conclusion that sounds from the proposed activities will occur outside the hearing frequencies or below sensitivity thresholds for marine mammals. See 550.261(c)(5) 30 EIA The EIA states: There is substantial information available, including cataloged 61 3.14.4 locations of dens, which would contribute to the avoidance and mitigation of disturbances to denning polar bears. Summarize and cite this information. See 30 CFR 550.247(a); 550.252(b)(1) and (2) 3.17.3, 3.17.4, Specify and describe any resources utilized outside of the state. See 30 CFR 31 EIA 69-71, 93, 96 4.3.2 & 5.3.2 550.261(b)(7) 32 EIA 69-71 3.17.3 & 3.17.4 Provide supporting information for the benefits information as a result of the DPP's proposed activities. Provide additional information on where the benefits are, when they occur, who benefits, and how. As an example, include information on government(s) revenue, employment, NSB vs Alaska benefits, NSB (population, wages, jobs), other NS O&G producers, and workforce. Describe any impacts to government revenues, Federal & State Royalties (Permanent Fund), and Taxation (Production Tax, Property Tax, and other relevant taxes). See 30 CFR 550.261(b)(7) Page 7 of 8 Bureau of Ocean Energy Management Liberty DPP Request for Additional Information Item Number Document Page # Section December 26, 2024 ENCLOSURE 1 Request for Additional Information 33 EIA 69-71 3.17.4 In the sections on Effects on Social Systems, describe the demand on social systems, and include a trend analysis, as well as any analogue project discussions. See 30 CFR 550.261(b)(7) 34 EIA 35 WCCP Outline 93, 96 4 4.3.2 & 5.3.2 Provide additional detail specifying impacts within Section 4, Cumulative Impacts and Section 5.3.2. Example information of what can be included: How does additional production affect any shared costs with other producers, tax revenues to local and state governments, with increased resource utilization of existing labor and infrastructure. Would the duration of facilities lifespan at Endicott and employment be impacted from development of Liberty? Include any population impacts to regional/local governments. Describe revenue and job impacts in the NSB and Alaska governments. 30 CFR 550.261(b)(7) Source Control - Relief Well Location and Timing Please provide more detailed information on the Innovation Rig, identified as the relief well rig. The WCCP states that the Innovation Rig will be brought on scene in the case of a blowout and it can cross the Endicott causeway bridges and be available regardless of season; however, Section 9.5 of the DPP states that the relief well rig has to be transported by ice road. The WCCP also notes that the Innovation Rig is in the region but more specifics should be provided. See 30 CFR 550.243(h) Page 8 of 8 Bureau of Ocean Energy Management Liberty DPP Comments and Clarifications December 26, 2024 ENCLOSURE 2 Item Number Document 1 DPP Page # Section Comment/Clarification For the map submitted under 30 CFR 550.241(b), show the surface location and bottom hole location of each well and also the bathymetry. Proposed wells SDI-01 through SDI-04 bottom holes should be added to plan view maps. Approximate well paths from SDI should also be included on the map. Please enhance/clarify the map figures to include a clear delineation Figure 1-1, Figure 1- and labeling of both Endicott islands and existing flowline system, as described in the text, as 4 2 well as any other "supporting onshore facilities" or "existing North Slope infrastructure" (mentioned in the text on page 2 as supporting the Liberty project) that are not on the current maps. Bathymetry on maps should have color that is distinct from what is used to mark the coastline. Seasonal ice roads should also be included on the vicinity map (Figure 1-2) that was submitted in support of 550.257(e) 2 DPP 5 Table 1-1 Include any potential authorizations associated with ice road construction, if applicable. 3 DPP 6 DPP Table 1-1 Regarding Section 7(a) ESA, note that consultation may need to be reinitiated for spectacled eider. See previous Liberty FWS ITS of 8 eiders due to collision, July 15, 2018. 4 DPP 11 Table 1-2 A Coastal Zone Consistency determination is not required because Alaska does not currently have a Coastal Zone Management Program. 5 DPP 13 Table 2-1 "Open Water" season generally occurs weeks earlier than Aug 1 in this area (e.g. EIA section 3.4 Appendix A - Amendment 2, Bonsell and Dunton 2018) 6 DPP 13 2. Schedule The referenced Form is identified as BOEM-0137, not BOEM-0317 7 DPP 3 SUBSURFACE Clarify if wells will be horizontally drilled through the Kingak Shale to reach the Kekiktuk Formation where the Liberty prospect is located. Figures relaying information about geological description of Liberty prospect should have Figure 3-2, Figure 3- either captions or legends detailing the information. Show the depths of expected productive 8 DPP 16-17 3, Figure 3-4 formations and locations of proposed wells on the structure contour maps. Add a key to Structure map on Figure 3-3. See 30 CFR 550.244(b) 9 DPP 19 DPP Fig 3-5 Please provide legend for Map figure, and ensure accurate labeling. Page 1 of 8 Bureau of Ocean Energy Management Liberty DPP Comments and Clarifications December 26, 2024 ENCLOSURE 2 Item Number Document 10 DPP 11 DPP Page # Section Comment/Clarification 21-22 3.3 Reservoir Development Plan Describe the reservoir management plan in more detail with respect to well spacing, the enhanced oil recovery techniques that were considered, and conservation of resources. See 30 CFR 550.246 and 550.203 3.2.2 Reservoir Reference oil analysis that assessed or tested for the presence of heavy metals, which could significantly impact air quality during emergency flaring. See 30 CFR 550.249(c), 30 CFR 21 Fluid Properties 550.243(c)(2) 3.7 Hydrogen If available, include a reference to a more recent H2S concentration analysis from a 12 DPP 23-24 Sulfide comparable well. See 30 CFR 550.245 Clarify if there will be any seafloor disturbance associated with the DPP, including along rig 13 DPP 23 DPP 3.6 transport corridor, and confirm adequacy of previous surveys for the ice road routes. See 30 CFR 550.194 Section 5.1 Design Provide more information on Hilcorp's proposal to inject produced gas from Liberty (OCS) 14 DPP 26 Basis into the Endicott Reservoir (State-managed). 15 DPP 27 5.5 Fuel Gas Clarify whether Hilcorp's intent was to cite BSEE (not BOEM) for the appropriate federal agency to discuss allocation of fuel gas. 16 DPP 28 5.6 In Section 5.6, Clarify whether Hilcorp's intent was to cite BSEE (not BOEM) as the appropriate federal agency to discuss potential commingling Section 5.6.3 17 DPP 29 Sampling and Provide more specificity on how often the well samples would be collected. Calibration of MPFM 18 DPP 30 Table 5-3 Include estimated volume of Methanol use. 6 Drilling and Well Include a figure showing how proposed Liberty ERD wells compare to the other referenced 19 DPP 31 Completions ERD wells (e.g., on the North Slope and other parts of the world). See 30 CFR 550.243(e) Page 2 of 8 Bureau of Ocean Energy Management Liberty DPP Comments and Clarifications Item Number Document Page # Section 20 DPP 32 DPP 6.1.2.2 December 26, 2024 ENCLOSURE 2 Comment/Clarification Other service units are mentioned in the last sentence of this paragraph. It is unclear if adverse impacts could be associated with "other units". Please clarify Sect 3.2.3 Estimate Based upon the reservoir model used to generate the reserves estimate, include estimated 21 DPP 34 of Recoverable Reserves - areal extent of the reservoir. The DPP states that the fresh water used for drilling will come from permitted sites: please 22 DPP 38, 43 DPP 6.3.3, 7.1.1 include the volume and frequency of these withdrawals, and specify if surface water sources or wells. For surface water, include an estimated size of the source water body. See 30 CFR 550.261, 550.257(c) 23 DPP 40 Table 6-4 Spell out NAF in table (e.g., Non-aqueous fluid) 24 DPP 42 6.6 Provide the specific state and federal requirements referred to for the lined and bermed mud plant. See 30 CFR 550.243(a) Discussion on power supply for the Rig 26 at SDI should be summarized here. Clarify if Section 7.1.2 highline power generated at the MPI will be enough to support Rig 26 in addition to 25 DPP 43 Electrical Power operations at the MPI itself. Describe what other electrical components are required to bring and maintain power to SDI. Ice roads as shown in Figure 7-3 do not appear to be sufficient for transporting Rig 26. The DPP states that Rig 26 will be transported on ice roads and underneath causeway bridges 26 DPP 47 7.2.2; Figure 7-3 providing access to the south side of the island. Rig 26 consists of multi-story modules that could potentially exceed the clearance under bridges. Please show feasible routes on a figure or confirm that there are no issues with transporting rig modules/components beneath causeway overpass. 27 DPP 47 7.2.2 Describe if ice roads have been constructed or used in the past near Endicott (MPI or SDI) or near the Causeway. Page 3 of 8 Bureau of Ocean Energy Management Liberty DPP Comments and Clarifications December 26, 2024 ENCLOSURE 2 Item Number Document 28 DPP 29 DPP 30 DPP 31 DPP 32 DPP 33 DPP Page # Section Comment/Clarification According to Table 1-2, this section aims to respond to 30 CFR 550.252(a) Monitoring 8.1.2 Marine Systems; however, environmental monitoring systems (e.g., weather variables, sound, air 53 Mammal Monitoring pollution, light pollution, etc.) required by 550.252(a) are distinct from the marine mammal monitoring systems required by 550.252(b). DPP, 8.2 Please provide clarification on if existing permits cover projected Liberty discharges. See 30 54 Discharges CFR 550.243(a) Describe the potential for emergency flaring during development and operations. Include any 55 8.3.2 information on the flare height, maximum brightness and duration of flare(s), and estimated flaring rate/frequency if emergency flaring were to occur. 8.3.1 Projected The SDI distance to shore is provided. Also provide the distance from MPI to shore, and 55 Emissions between MPI and SDI. See 550.249(d) Air Clarify if there are any three-phase production processing steps at SDI, or if all the processing is done at MPI. 57-61 8.4 Waste Management The DPP references the Liberty Waste Management Plan, integration into existing Endicott procedures, the Alaska Waste Disposal and Reuse Guide (Revision 11, October 2021, or North slope facility(ies) for managing waste streams. Please provide more specific information on the facilities that will be receiving waste streams, and their locations. See 550.258(d) 72-73, Section 6, If not already planned, HAK is advised to consult with both the Native Village of Nuiqsut and the Nuiqsut Whaling Captains Association at its earliest convenience regarding the amended 34 DPP EIA 97 Consultation DPP, and update the list on page 97 in Appendix A, Section 6. See 30 CFR 550.261(d) Section 9 Oil and When more information is available on Hilcorp's oil spill response plan and associated BSEE 35 DPP 65 Hazardous Substance Spills requirements, please include in the DPP. See 30 CFR 550.250(a) Page 4 of 8 Bureau of Ocean Energy Management Liberty DPP Comments and Clarifications December 26, 2024 ENCLOSURE 2 Item Number Document Page # Section Comment/Clarification Specify if there would be any period of time during hydrocarbon zone drilling when a secondary rig cannot be transported via ice road to drill a relief well on SDI, in the context of seasons. According to Table 2-1, drilling in the hydrocarbon zone begins Nov. 01, 2028. Table 2-1, Section However, the relief well rig constraints in Section 9.5 list the primary constraint being 36 DPP 13, 67 9.5 Description of mobilization of another rig to transport over ice roads, which cannot be constructed until at Worst Case Discharge Scenario least December or January. Confirm that there is secondary rig on-site or one that is capable of drilling relief wells and can be transported over the causeway for the proposed November start. Please describe here at a high level, and address in more detail as Hilcorp initiates other relevant permit applications. See 30 CFR 550.243(h) 37 DPP 74 Lighting of Lease Structures to Minimize Effects to Spectacled and Steller's Eiders: Although 11.9 the Liberty project is classified as a development project and not an exploration project, BOEM encourages HAK to implement lighting protocols to lessen impacts to both eider species. Please include estimated decommissioning schedule. (In particular, because of potential bird 13 DPP Table 2-1 and attraction/collision hazard from the lighted rig, how long will it be present and operating in the 38 DPP 76 DecSoemcmtioisns1io2ning coastal project area, including on the SDI and any nearby staging? How many spring and fall migration seasons will it be present?) 39 EIA 40 EIA 41 EIA 2.2- Proposed Paragraph 2 closes with "No flow testing or well test flaring are planned for this drilling program." and is directly contradicted in Paragraph 3, which opens with "HAK first plans to 6 Action drill the first well and conduct flow tests....". 2.2- Proposed "up to four producing wells and one water injection well" is inconsistent with what is 6 Action described in the Liberty DPP Amendment 4 6 2.3- Alternatives Not Clarify why these alternatives were not carried forward. Carried Forward The final paragraph describes the differences in water levels from the 1980s to now, but 42 EIA 21 3.4.3- Water Levels closes with a statement about the 2000's, which is in the middle of the time frames previously mentioned. More explanation and citations are warranted. Page 5 of 8 Bureau of Ocean Energy Management Liberty DPP Comments and Clarifications December 26, 2024 ENCLOSURE 2 Item Number 43 Document EIA 44 EIA Page # 23 24 Section Figure 3.4-1 3.4.6.2- Effects of the No Action Alternative on Air Quality Comment/Clarification Is landfast ice data from 2017 the most current data available? Suggest updating with more recent data. The header title incorrectly says "Air Quality" instead of "Oceanography" 45 EIA 27- 29 3.6.4 Clarify by providing graphics depicting noise radii for drilling, etc. See 30 CFR 550.261(c)(1) 46 EIA 29 47 EIA 30 3.7.1 3.7.1 Citation following first sentence of 3.7.1 should be replaced with more up to date information. This information is out-of-date (from 2010). Impaired water lists are updated yearly by ADEC. Please provide up to date citation following first sentence of this page 48 EIA 34 Figure 3.8-1 For the shaded polygons, please indicate that the percentages refer to percent rock cover. 3.8.3.1 Final 49 EIA 36 sentence of This information is out-of-date (from 2012) and should be updated. subsection 50 EIA 40 3.10 Steller's eider breeding habitats are located west of the Liberty project, not east as stated in EIA. 51 EIA 54 3.13.2 The data provided for Muskoxen population numbers in the project area is from 2011 and 2013. Please provide more up to date information if available. Please explain whether or not the North Slope Borough would be collecting new/additional Section 3.17.4.1, property taxes or other related revenues if this project was developed. Also, describe the 52 EIA 71 fifth paragraph effects to the NSB economy either from additional revenue or no additional revenue associated with this proposal. See 30 CFR 550.261(b)(7), 30 CFR 550.247(c) Section 3.20.4.1 Within these pages, impacts to the bowhead whale subsistence hunt staged at Cross Island 53 EIA 83-89 and Section 3.22.3.1 by the Nuiqsut whalers should be addressed. See 30 CFR 550.247(c) Page 6 of 8 Bureau of Ocean Energy Management Liberty DPP Comments and Clarifications December 26, 2024 ENCLOSURE 2 Item Number Document 54 EIA Page # 89 Section Section 3.22.3.1 Comment/Clarification Subsection title 3.22.3.1 could be clarified as: Effects of the Liberty Project from Spills. 55 EIA 92 56 EIA 94 The EIA addresses cumulative impacts for Air Quality, Social Systems/Economics, and Oil or 4.3 Hazardous Material Spill. Although cumulative impacts for all other resources may not have appreciable impacts , they still could be addressed for any kind of future NEPA analysis. 5 Clarify if Hilcorp intends to comply with relevant wildlife mitigations from OCS EIS/EA BOEM2016-010 to include speed limits, while operating onshore. 57 EIA 93, 96 4.3.2 & 5.3.2 Clarify if impacts to existing infrastructure lifespans outside of Endicott are anticipated 58 Seismic Lines B-2, B-4 59 Seismic Lines B-4 60 BOEM-0137 2, 6, 10, (proprietary) 14 61 BOEM-0137 3, 7, 11, (proprietary) 15 62 BOEM-0137 15 (proprietary) 63 BOEM-0137 7 (proprietary) 64 BOEM-0137 4, 8, 12, (proprietary) 16 Map is difficult to read, as there are overlapping labels, no scale, and no north arrows Bottomhole location for SDI-03 is the same as coordinates listed on Appendix F page 7, SDI02 Clarify schedule for each well because as written they appear to all be drilled at the same time. Include the Lambert X-Y coordinates and blockline departures for well locations. Verify the Coordinates for the SDI-04 bottomhole location. Coordinates for SDI-02's bottomhole location are at the same location of SDI-03 on the map on page B-4, Appendix B Confirm the value of the "Estimated Net Sand Height MD (Net Pay if hydrocarbon)" to ensure consistency with values in WCD Modeling Report (Appendix D) Table 6-1 for the length of the producing horizontal lateral in the reservoir. Page 7 of 8 Bureau of Ocean Energy Management Liberty DPP Comments and Clarifications Item Number Document Page # WCD Modeling 65 Report 14 (proprietary) Section Figure 10-2 December 26, 2024 ENCLOSURE 2 Comment/Clarification Label where the oil column is penetrated on the Profile/Directional Plan diagram within Figure 10-2. In addition, ensure consistency between the reported table values and the diagram: specifically in Section 1 and Section 2 for build rate. WCD Modeling 66 Report (proprietary) 67 WCCP Outline 2 68 WCCP Outline 3 Reference any map of net pay and permeability thickness that was generated to help develop the WCD models. The previous DPP had a net pay isopach and permeability-height (Kh) maps generated to depict hydrocarbon accumulations within the Liberty reservoir. Pressure Control Equipment Source Control - Well Capping Clarify whether Hilcorp's intent was to cite BSEE (not BOEM) in first paragraph on pressure control equipment. Provide an estimate of how long it would take for well-capping to occur. Also provide more detail on the well ignition techniques described in the Contingency Plan for Loss of Well Control Page 8 of 8