MEMORANDUM

TO: Commissioner Mark Williams, GA DNR

FROM: Doug Haymans, GA DNR Coastal Resources Division Director

DATE: November 29, 2018

RE: Environmental considerations for offshore oil and gas exploration and production

In response to your request for information following the January 2018 call for public comments from
BOEM regarding the potential for oil and gas development in federal waters off the coast of Georgia, the
Coastal Resources Division, in cooperation with the Wildlife Resources Division (referenced collectively
herein as “DNR”), submit the following information for your consideration. This document is a summary
of existing information and should not be considered inclusive of all the natural resource considerations
related to the exploration and development of offshore oil and gas.

DNR’s findings in this document are similar to those expressed in your August 27, 2017 letter to
Department of Interior Secretary Zinke and are described in three broad categories of impacts from oil
and gas exploration and production: 1) the physical environment, 2) the biological environment, and 3)
socio-economic factors. A more detailed discussion of these categories can be found in the Technical
Addendum to this memorandum. Also, within the Technical Addendum is a description of an offshore site
selection tool developed by the CRD’s Georgia Coastal Management Program in partnership with the
Georgia Institute of Technology. This tool, in part, enables the geographic visualization of many of the
resources under consideration in this document.

This memorandum also does not contemplate what is yet unknown about the effects of onshore oil and
gas support facilities (e.g., refineries), changes in vessel traffic transporting crew and product to and from
production sites, or other aspects of the offshore oil and gas industry not yet considered.

Physical Environment:
Oil and gas exploration and production may have potential impacts to groundwater, offshore hard
grounds, and on other mineral resources on the continental shelf, as well as to nearshore and inshore
environments. Over 600,000 residents living in 6 coastal counties of Georgia depend on the Floridan
aquifer for their drinking water supply. Previous drilling on the Georgia continental shelf demonstrated
that the aquifer extends at least 55 miles offshore. Protection of this aquifer is of critical interest to
Georgia. The Floridan aquifer is currently protected under Official Code of Georgia Annotated (O.C.G.A.)
§12-5-90 et seq., and the “Coastal Georgia Water & Wastewater Permitting Plan for Managing Salt Water
Intrusion.” Exploratory and production drilling that adhered to the Georgia Oil and Gas and Deep Drilling
Act (O.C.G.A. §12-4-40 et seq.) would minimize potential impacts to this resource.
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Exploration or development of oil and gas in waters off Georgia must take into account the presence of
other mineral resources on the shelf including phosphates, gas hydrates, and heavy mineral sands. Mining
in Georgia is regulated under the Georgia Surface Mining Act of 1968 (O.C.G.A. §12-4-70 et seq.) and
phosphate mining under O.C.G.A. §12-4-100 et seq.

Offshore hard grounds are areas where consolidated carbonate rocks are exposed on a broad, gradually
sloping continental shelf otherwise dominated by unconsolidated sands. They are also likely locations of
freshwater springs where the Floridan aquifer discharges into the ocean, which may affect surrounding
biological diversity. These rocks also provide the firm foundation needed for the development of unique
ecosystems dominated by sponges, corals, ascidians, and other reef invertebrates. Commonly referred to
as “live bottoms”, these scattered hard grounds are "hotspots" of biological diversity on the continental
shelf that support many commercially and recreationally important fish, as well as provide habitat for sea
turtles and marine mammals. Since hard grounds comprise less than 10% of the continental shelf off
Georgia, the biological and social-economic importance of these areas is exceptional.

Georgia’s nearshore and inshore physical environments must also be considered when accounting for
threats from oil spills. Georgia’s nearly 370,000 acres of coastal marshlands account for approximately
one-third of the salt marsh remaining on the Atlantic Seaboard of the United States. The estuarine
marshlands of coastal Georgia are among the richest providers of nutrients in the world, provide a nursery
for commercially and recreationally important species of shellfish and other wildlife, provide a buffer
against flooding and erosion, and help control and disseminate pollutants. The marshlands also provide a
natural recreation resource which has become vitally linked to the economy of the entire state. Salt
marshes are costly, if not impossible, to reconstruct or rehabilitate once impacted. These areas are
primarily managed through the Coastal Marshland Protection Act of 1970 (O.C.G.A. §12-5-280 et seq.)
and the Coastal Management Act (O.C.G.A. §12-5-320 et seq.).

Fourteen barrier islands, sand dunes, beaches, sandbars and shoals make up Georgia’s sand sharing
system which protects coastal property from the damaging effects of floods, storm surge, wind, tides and
erosion. Georgia’s beaches provide a tremendous natural recreation resource which is linked to the
economy of the entire state. The sand sharing system is managed primarily through the Shore Protection
Act of 1979 (O.C.G.A. §12-5-230 et seq.) and the Coastal Management Act (O.C.G.A. §12-5-320 et seq.).

Biological Environment:
Sustained by the estuarine system, Georgia's coastal and offshore waters are highly productive and
support an abundance of marine life. These waters and the State's unique series of undeveloped barrier
islands and beaches also provide critical feeding and nesting habitats for several endangered, threatened,
or rare species. These areas are largely managed through the Coastal Marshlands Protection Act of 1970
(O.C.G.A. §12-5-280 et seq.); the Coastal Management Act (O.C.G.A. §12-5-320 et seq.); the Georgia
Natural Areas Act (O.C.G.A. §12-3-90 et seq.) and the Protection of Tidewaters Act (O.C.G.A. §52-1-1et
seq.). Endangered species are protected under the Georgia Endangered Wildlife Act of 1973 (O.C.G.A.
§27-3-130 et seq.).

Approximately 32 species of marine mammals occur on the Georgia continental shelf including threatened
West Indian manatees and critically endangered North Atlantic right whales. Five species of endangered
or threatened sea turtles occur on the Georgia continental shelf, including the green, hawksbill, Kemp's
ridley, leatherback, and loggerhead sea turtles. Other endangered species or species of concern occurring
on the Georgia shelf include fish (Atlantic sturgeon, shortnose sturgeon, and smalltooth sawfish) and
marine birds (least and gull-billed terns, piping plover, and American oystercatcher).
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Georgia’s estuarine and offshore waters support a rich array of marine fishes including finfish and
shellfish. Many species utilize both inshore and offshore waters throughout their life cycle, with estuarine
marshes and oyster reefs providing essential nursery and foraging habitats.

In addition to coastal barrier islands and beaches, other habitats of concern include those protected or
recognized under federal and/or State law, including Wassaw, Blackbeard, and Wolf Island National
Wildlife Refuges; the State's protected "Bird Islands"; Ossabaw Island Heritage Preserve; Gray's Reef
National Marine Sanctuary; Sapelo Island National Estuarine Research Reserve; Altamaha Biosphere
Reserve, Cumberland Island National Seashore, and designated critical habitat for loggerhead sea turtles
and right whale calving.

Socio-Economic Environment:
Concerns include potential impacts on the State's historical and cultural resources, as well as on present-
day industries and initiatives. Georgia's coastal region is rich in cultural resources that represent a long
history of habitation by man. Reflecting a rich maritime tradition, several known historical shipwrecks
occur on the adjacent continental shelf, although it is likely that many more wrecks remain
undocumented. These resources are largely protected through Georgia's Submerged Cultural Resources
Act (O.C.G.A. §12-3-90 et seq.).

Georgia’s coastal zone also supports industries vital to the State’s economy, including commercial and
recreational fisheries, port traffic, and tourism. Tourism in coastal Georgia as a nearly $2 billion/year
industry. Georgia's deepwater ports and inland barge terminals support more than 339,000 jobs
throughout the state and contribute $84.1 billion in revenue to Georgia's economy. According to a recent
economic report, NOAA Fisheries Economics of the U.S. 2015, estimated that the economic impact of
recreational saltwater fishing to Georgia's coastal community included $142.3 million in sales, $58.7 of
income and $131.8 million in trip expenditures. Georgia’s commercial fishermen landed 7.1 million
pounds of seafood with an ex-vessel value of $16.8 million.

Georgia’s unique coastal and offshore environment is vital to the State of Georgia and its citizens.
Exploration and development of offshore oil and gas could have significant ramifications to state
resources. It is hoped that this memorandum and the following Technical Addendum will aid the decision
process as the State carefully considers the future of energy production on the Georgia coast.

Currently, CRD is unaware of any new opportunities to provide comments to BOEM on the proposed
leasing plan since the last call for comment in February. However, we do anticipate future coordination
with BOEM when the draft EIS for the proposed 2019-2024 plan is publicly released, at which time
additional public comments will be accepted. We hope that the findings articulated in these documents
continue to provide useful information on the potential environmental considerations for oil and gas
development off our coast.