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NRMD Staff Report (STD-87-2C) ` /� 4 <' � TZ} F/� R E PrR /- - S7D - S-7-2(, • /lt�{D �� • ]-u^Jj� /7 /7�-7 �] / �7 r enic�les. The proposed swamp buies wiIl- weih abmut 18, 0@0 when icaed with the "standard drill" co be used and wiII terra tires (wide tires, see picture, pae 2�, Attachment A). o. 2n "heavily. vegetated <fores±ed} wetlands" they oropose to use portable drill= on atc' s or hand carried. Some forested wetlands they will 'delete' from .the seismic program. 1. 2n Attachment A, page 30, they describe "portable , drills" to be used as those that can be broken ucwr into 5-10 ` � packages of t00-1521 Its each. , 2. 'Small drills" are defined on babe 30 <attachment A} to be mounted on trailers 4�F.f x 106 inches} that would de pullet Py a small four wheel drive tractcr. trailer and tractor . would have the terra • tires. These would be used in "environmentally sensitive' areas, primarily in heavily wooded systems. NRMD COMMENTS 1. •Staff concerns are twofold. • a. The current • petition • for seismic testing with its botertzal • necat1ve impacts. 1. • Destruction of vegetation and routing of wetland soils. 2. Disruption of wildlife behavior patterns because of enhanced human activity, vehicles, and ~--.• 1 blasting. Esoecially important • is potential - effects on protected species. b. The "Iarger picture" of cumulative impacts on the wetlands and other habitats, and the protected species, of an obvious escallation of oil related activities in a natural preserve and other ecologically important wetianos. **************************************************************** . Both a and t above must be addressed in the ST permitt ind process ` • ir order to assure continued viability of these ecosystems. **************************************************************** / 2, NR>*0 staff 'has reviewed the petition and 1 :400 scale aerials , provided', but nas not had the opportunity to "ground truth" all of the 45 miles of lines in Collier County. 3. :n early ciscussioms with the petitioner, production of a Collier County Environmental Impact atonement by Shell Western . for the prio(osec activities was discussed. The petitioner stated that they were fairly far along in tne State permitting process ant reduestec t`at information suomitted to the • I}. E. 'i. te accepted in Ilea of an E. :. G. D~. E. Proffitt verbally told Dr. ( aerbert trat tnis was nut acceptaole as an E. I. S. , but in the interests of not undueiy stalling tneir project too far into the . rainy seasor that ; < 1 } the material submitted to the State ~=� would be ~eviewet; '(2) the petitioner would present at least one \ workshop session to the 'E. A. C. concernint thei.r proposed activities • (tais was done} ; a 3) a m ! entficall lnat adoresseo the general effects of oil-related activities in the Big Cypress Preserve and Area / of • 1 e- I ye I .2, ee , 1 1 Critieal State Concern would be produced ant submitted prior or I a:..dno with any additional ST development petition for oil 1 - eseeted activities that might occur in tee future. No oojection I was raiser to this at the tima ane thes teis requirement will b I e stipulaticn of approval of the current 37 petitiorer [ 4. Staff has reviewet two seientiFie papers on the subject of tie ef.Fer:t,,,, ri-F off rhad vehie ; es, antattented ona seminar on tne , 1 sebject. The pertinent findinps of these studies are semmarizen '. below. _ , 11 REVl: EW 0 ,--7 SCIEN7 IF : C PAPER tri:: 11 il A. Duever. Carison„ ant Rio2elip 1S6 ,.- L -Road vei.cles fr and their ieei,-;:ets In .'zhc-::, E,f..:7 Cypress Nat crel Presprye. Report 7- tI 614, South '-'lloriea Researce Center._ 214 pb. Ft 1.. An experiment was condueted to test the impacts of I roes types of off-road vehieles ',See 7adeie 1, adaptee from Duever et al. 1961 reprinted on the ' ir next page of this report ) . (.1 E. One-year recovery of experimental plots in different I Lieabitats (from eane 17Z and -Fable 113 of the cited paper) a. The severity of neeative impact varied with: 1 1. the type of the vehiple Ir e•-•• a) aireoat, wheeled vehicle ':witeout and with 11 ' chains) , and track vehicle J b) wei7„et of t:!--a vehiele 2. thp number of nesses a divan ve- ele type mate. 3, the type of hapit,Tt, _ . ri e . . - .- ' e ' ' .e ii,,' - ''T-I `.1. ,,,, ,,' 1,..,,. ' ,`. .. ':,`:.'t Al, ' , ...f. .. 0, Onezyear habitat reepvery relative tf7]: habitat tyce 1. Pine flatwoots ead the best recovery -, .. .. ..- . , e 2. Sand marsh reeovered almost es wel/ as pine flat woods . . , ...._ II. - .3. .7,arl marse, small cypress, and peat marsh habitats: None of these habitats reeovered e, , within a year, even under " low impact" 4.:,ne-bass) experimental treatment. • . c. Cr;e-veae heeitet .ceeev?ry eje:lative to vehicle tvpe„ ::::,a-.; ereatmene allowed virturaily eemp_e_ e eeeoveey e. :.2,I1 .:::: .-ria veeicies at eeeiem are eeavy exeerieentel ieeact levels resulted :en ets eeat entered east eee . y:,..,.. 1- t-i?X7_7: ',—.,. ,:ieY't-, 1 iDe',—.., s. '--. - ,1-.3. : :::!,,,, i1-) :. level k,:e.le-pass per veniele) . I . . ... . a.: 7.4 7 :,:.' 7z;r:-.-.::ot;..—i.:-.i.11-e .-."s c..- Ei 1 I Ccv•': ...-..1/4 more reeovary- than oi.: ther b ,cg:,-as with tiree-e - • e tnis may. ee'ie teen an exterieental ertifact since it would not • . _ . . , , , .,.... . Dperate -.0-1---ailfhabitats. F-.) No bu2cy consistently alloweb better- ' 1 . ..„ i 1 3 • ENVIRONMENT,+L _ADVISORY COUNCIL JUNE 17, 1987 • M�o_Herbert,, Consultant for Shell Western E & P, Inc. , stated he has met with Staff since the last meeting and all con- cerns have been addressed. He stated they addressed the issue of , cumulative negative impacts and have resolved this issue to everyone's satisfaction. He said the Staff recommendations now reflect what has been egreed Natural Resources Management Director Proffitt stated that after many discussions with Shell Wrn noandutith Staff members, he would like the EAC to adopt a policy Preserve involving oil-related activities within the Big Cypress and Area of Critical State Concern. Mr. Cardillo stated that these are really two different issues and suggested that the Board hear the Shell Western peti- tion and discuss the policy statement issue during the Addenda portion of the meeting. Dr. ions tProffitt stated that however, insteadnoftdemandinglexact con- form to the Duever Studies, PSI's it r limits to Heavy,saidmedium, newor light reC recommendations alsodefined requirey the Dwhenr Group.e that when there are existing trails, Shell will use those trails; periodic inspections by NRMD; and language with regard to restoration. • In answer to Dr. Benedict, Dr. Proffitt stateo da e NRMD will.es review the raw data which Shell is supe Y 9s and see if they agree. Mr. Herbert statedithatihe t he isecinfident tthat they will be able to supply tion he requires. Dr. Benedict stated that this is more or less a test case. Mr. Herbert advised that Shell Western will abreaseekinngtamper per- mit to expend their lines into the Big CyPrwss snd August. He said and will be doing extensive research in July He EAC will have that data for evaluation in September. be also to o advised that by keeping this time schedule, they keep a continuous crew. Dr. Proffitt added that Shell will pro- lines so vide data fom evaluaterthetexactrlevels he fist sofcimpact on the Dr. Benedict moved, seconded by Kr. Below and carr • mously, that Petition STD-87-2C, Shell Western E i P, of requesting permission to conduct abOutrforty:ndve files approval seismic testing in Collier County, be subject to the following stipulations: 1. The standard Buggy Drill (18,000 lb. machine) : Page 3 t)1.) WW f;=1,:244 °.-_---^ . . ^ P/a/ifi/� in/5.5 � rr\ (A trin c:)._„ar, ~� ` . ' '~� x ' QF THE ENVIRONMENTAL ADVISORY COUNCIL TO THE ' ^ '^ '~'` ~~'` COLLIER COUNTY PLANNING COMMISSION REGARDING PETITION 87-2C° , ! SHELL WESTERN E & P REQUESTING PERMISSION TO CONDUCT APPROXIMATELY 45 MILES OF SEISMIC TESTING IN AREAS ZONED ST INCLUDING PORTIONS OF THE BIG CYPRESS AREA OF CRITICAL STATE ' CONCERN. 'r. `.~' • ` � . - `� ' 1 � � / . , / - x � � .` ' . .° ^ ' ` ' NOTE: The recommendations cited tTerein are those adopted by the Environmental Advisory Council 17 June 1987. ' ~ _ - ` . . CONSIDERATIONS: ` ' ' . _ � ` .. ' `:= . ` ` - ^ 1 � Shell Western has requested to conduct 140 miles of seismic testing of which about 45 miles are in Collier County. Most of . . g Cypress Area of Critical State Concern and ' i Mmiate1y ~,` ' ' djacent to the Big Cypress National ^ Preserve, .. ' . |�~� .`�� ` ^ ` '` ` � �' ` ` ` � / `' ' '�` �� , � , ^ ' 2. Seismic testing will be via 0.SS to 2.0 pound blasting charges in 28 foot deep holes. | . S. The seismic testing will be conducted ' 0 feet or so _ ~ � � ~/ along. 5 linear transects. • The a proximate�totalnumber�of "shot � '� , .~. holes" to be blasted in Collier County will be 7,043 in this Si^ '. , petition. , ^ 4. The seismic crews will use a variety of techniques es and vehicles to accomplish their work . These will include: - ` ^ a. Using "Standard Buggy Drill " which with :a swamp buggy ', .� .� 'weighs 18,000 lbs, �- and support vehicles in open '' and readily .' /' ,, accessible habitats including "open wetlands" . ^ They define open areas to be those with tree spacing of 12 feet o' r greater . ` b. Using lighter weight ( 1000 total pound )' "Small Drills" : mounted on trailor and pulled with a small tractor in `'habitats^ � . where tree spacing from 12 feet to 4 feet . ^�`, � ' �� � ,`,. � c . Backpacking portable equipment into densely wooded . areas, or very wet and/or sensitive habitats where use of the other equipment listed in a and b would create adverse ' impacts on the native vegetationand soil regime. . ' ' ' ` ' � `' � order to allow the seismic activi --to-- begin prior, to �getting toofar into therainyseason t' e EAC and Natural ge ng , n Resources Management (NRMD) staff agreed to accept information given to the Florida Department of Environmental Regulation in lieu of a Collier County Environmental Impact Statement (E. I .S. ) on the condition that a scientifically sound and quantitative E. I .S. be produced prior to issuance of any future ST permits for oil wells, roads, or support facilities. This E. I .S. shall have to address the ipnoacts of the specifically p[oposed ST Kdevelop��ent petition as well as cu[Dulatiye imgaet�� of oil 1 ` ^ . `1 .� �'. ` ^ � � � ' _` � '� ' `~ exploration •and extraction activities in the Big Cypress Preserve and Area of fur itcat KState ,Concern. `easons `�' a ""‘• . be Teves at suth an 'intensive effor , is 'necessary 'are outlined ' in items zb .-. .9h (below)" that document oil activities in the Big Cypress Preserve ind ;Natior•ral Park Servicestaff projections of future efforts. 6. Current major oil-'-'related activities in the Big. '-Cypress Preserve (from "a Workshop presentation to the Environmental Advisory Council by Mr . ".Steven Hunt of the Big Cypress Preserve) . • ---------OIL FIELD•-- BEAR ISLAND - RACCOON POINT TOTAL WELLS (current ) 23 16 , Producing 1S .•,, 13 inactive 10 2 (being built ) salt,;water- disposal 1 F'ROF'OSED WELLS 8 = r 7 SOME WELL SPECIFICATIONS` , w err'" a. :aver,a a ife ;Of ,a well = '6O -S0 years b. well = 2 5 acres ...•, .. size of fill pact for a S• Big' Cypress staff -"best guess" as to ultimate pro ject r c±rrs` for , .. the future a, NEW .,OIL FIELDS <L I E.E BEAR ISLAND AND RACCOON PO I NTF ,c. . 1 ,., 1 . megapads per 'field 3 (minirnurn) , 2. wells • per field = 18 (minimum) I i-'t•t, Miles' -Of si~ijaport' 'rroads ` andstructures such as the' °Su.►nn'i land Pipeline have not been . documented here , in .. the :;:inter es,ts brevity. but obviously 'provide additional impact • 10. CONCLUSIONS: NRMD staff concludes from the , -above discussions, from reviewing scientific literature on the subject , and from workshop sessions with the E.A.C. that there is' a hii.gh probability that oil exploration and extraction, will greatly increase with the advent of a new major oil company :into the Big Cypress Preserve. The data necessary to determine if some upper- threshold level of oil-related activities exists, above which the Preserve will begin to deteriorate as a viable ecological entity, have not been gathered . Clea"r ly, such studies are needed . '` Clearly, via the Collier County E. I .S. ordinance, it is the responsibility of the petitioners to provide these data. The EAC 'Concurred with this conclusion 17 June 1967. 11 . Based on this conclusion, the E.A.C. at staff ' s recommendation, has adopted on 17 June 1987 a policy that for any 3.t N.fi p, ,. . . s _ . . -.Gt� t --n.'_vrn rt. .. .r ..y ... .... •>. s,Awr f: r r ,, •. y� '`#"�1}, � 04-t.;.,;- 4-rY '� .:•R'yi r - ,orf dy}� _ ..•�2.� .� ✓�, .. .... .v.S+ ._ .:.J.. T r.r ., K fn. $k�. �. W,. i 4.fit .'.fit N. .Y•... -fr'J.ttv. f- 1 r)END.T X 4 'jil: ! Executive Summary , 1 Shell Western E & P, Inc. Page 2 _ i` 5. In order to allow the seismic activity to begin prior to getting too far into the rainy season, the NRMD agreed to accept information given to the Florida Department of Environmental Regulation in lieu of a Collier County Environmental Impact Statement (EIS) on the condition that ;' a scientifically sound and quantitative E.I.S. be produced prior to issuance of any ST permits wells, roads, or support facilities. This E.I.S. shall have to address the impacts of the specifically proposed ST development petition as well as cumulative impacts of oil exploration and extraction activities in the Big Cypress Preserve and Area of Critical State Concern.I Reasons that the NRMD believes that such an Intensive etfort 1s necessary are outlined in items 6-9 (below) that document oil activities in the Big Cypress Preserve and National Park Service staff projections of future efforts. 6. Current major oil-related activities in the Big Cypress Preserve (from a Workshop presentation to the Environmental Advisory Council by Mr. Steven Hunt of the Big Cypress Preserve) . OIL FIELD BEAR ISLAND RACOON POINT TOTAL WELLS (current) 23 16 Producing 13 13 inactive 10 2 (being built) salt water disposal 1 1 I PROPOSED WELLS 8 7. SOME WELL SPECIFICATIONS a. Average life of a well = 60-80 years. b. Size of fill pad for a well = 2-5 acres. 8. Big Cypress staff "best guess" as to ultimate projections for the future; a. NEW OIL FIELDS (LIKE BEAR ISLAND AND RACCON POINT) = 1-5 1. Megapads per field = 3 (minimum) . 2. Wells per field = 18 (minimum) . 9. Miles of support roads and structures such as the Sunniland Pipeline have not been documented here in the interests of brevity, but -- obviously provide additional impact. APPENDIX 1 PERMITTEE: Charles Shumway PERMIT/CERTIFICATION c/o William J. Johnson NO. 111000635 1250 Tamiami Trail North Suite 203-B DATE OF ISSUE: August 12, 19.86 - Naples, Fl. 33940 EXPIRATION DATE: July 31, 1989 SPECIFIC CONDITIONS: 1. The permittee is hereby advised that Florida law states: "No person shall _ commence any excavation, construction, or other activity involving the use of sovereign or other lands of the state, title to which is vested in the Board of Trustees of the Internal Improvement Trust Fund or the Department of Natural Resources under Chapter 253, until such person has received from the Board of Trustees of the Internal Improvement Trust Fund the required lease, license, easement, or other form of consent authorizing the proposed use." Pursuant to Florida Administrative Code Rule 16Q-14, if such work is done without consent, or if a person otherwise damages state land or products of state land, the Board of Trustees may levy administrative fines of up to $10,000 per offense. 2. Turbidity screens shall be utilized and properly maintained during the permitted construction and shall remain in place until any generated turbidity subsides. 3. The Punta Gorda Department of Environmental Regulation office shall be notified in writing 48 hours prior to commencement of work and upon completion of work. 4. No live-aboard boats shall be allowed. 5. No fuel facilities nor storage shall be allowed at the project. 6. • •rmative signs on proper boating techniques in manatee inhabitated waters all be provided at the docking facility. � 7. The m tigation zone in the proposed riprap revetment shall consist of potted ( ��► 18' m nimum height red mangrove (Rhizophora mangle) seedlings anchored at 5 foot intervals along the toe of the bulkhead. A survivorship of 80% over 3 - -.rs shall be required. Natural recruitment of mangroves and other wetland plant species to the revetment and planting zone shall be allowed. 8. The permittee shall, in coordination with the proper agencies, and adjacent reparian dockage, establish a no wake/idle speed zone around the project site. 10. Annual monitoring reports, with color photographs, detailing the quantitative and qualitative success of the mitigative mangrove plantings shall be submitted to the Punta Gorda DER office annually for three years. In the event the survival period extends beyond the permit expiration date, the permittee shall submit an agreement to the Punta Gorda DER office evidencing a continuing obligation to ensure the three year survival period beyond the expiration date. 11. The project shall comply with applicable State Water Quality Standards, namely: 17-3.0.51 - Minimum Criteria for All Waters at All Times and All Places. 17-3.061 - Surface Waters: General Criteria. 17-3.121 - Criteria - Class III Waters - Recreation, Propagation and Management of Fish and Wildlife: Surface Waters. riiec2ivelINovember530, 1982 Page 5 of 6 REVISION "A" STANDARD STIPULATION NO. 2 Native species shall be utilized, as described below, in the site landscaping plan. A landscape plan for all landscaping on the development shall be submitted to the County Landscape Architect and to a County Environmental Specialist for their review and shall be subject to their approval. The landscape design shall incorporate a minimum of 60% native plants, by number, including trees, shrubs, and ground cover. This plan shall depict the incorporation of native species and their mix with other species, if any. The goal of site landscaping shall be the re-creation of native vegetation and habitat characteristics lost on the site during construction or due to past activities. The only exception to the above shall be: where landscaping is required for parking lots and other small areas adjacent to heavy vehicular use, the groundcover component shall not be included in determining this 60% requirement. Under these circumstances, the re-creation of native habitat is recognized as being unfeasible. REVISION "B" STANDARD STIPULATION NO. 2 Native species shall be utilized, as described below, in the site landscaping plan. A landscape plan for all landscaping on the development shall be submitted to the County Landscape Architect and to a County Environmental Specialist for their review and shall be subject to their approval. The landscape design shall include native plant species to be utilized in the following percentages, by plant numbers: Native trees 70% Native shrubs 65% Native ground covers 40% As an alternative, a minimum of 60% native plants, by number, may be used, at the discretion of the County Landscape Architect or County Environmental Specialist. This plan shall depict the incorporation of native species and their mix with other species, if any. The goal of site landscaping shall be the re-creation of native vegetation and habitat characteristics lost on the site during construction or due to past activities. The only exception to the above shall be: where landscaping is required for parking lots and other small areas adjacent to heavy vehicular use, the groundcover component shall not be included in determining this native plant percentage requirement. Under these circumstances, the re-creation of native habitat is recognized as being unfeasible.