TECHNICAL ADDENDUM

Environmental considerations for offshore oil and gas exploration and development in Georgia.

1.0 Physical Environment

1.1 Groundwater
The major concern involving groundwater is the integrity and water quality of the Floridan Aquifer. The
Floridan aquifer is the primary source of water for public, domestic, agricultural, and industrial users
throughout southeast Georgia. At its peak, approximately 700 million gallons of water per day were
withdrawn from the Floridan aquifer in Georgia. Drilling in the early 1980's demonstrated that the aquifer
extends for at least 55 miles under the continental shelf.

Recent drilling on the shelf shows that a groundwater cone of depression in the Savannah area extends
eastward at least 15 miles from the shoreline. This cone of depression allows groundwater under the
continental shelf to migrate towards Savannah. The offshore portion of the aquifer is protected from
saltwater intrusion by a Miocene aquitard. Recent studies have shown that this aquitard is of variable
thickness on the continental shelf (ranging from 0 to 160 feet thick) and is susceptible to local erosion.
Exploratory drilling should be designed to prevent potential breaching of this confining unit separating
the Floridan aquifer from the ocean.

1.2 Hard Grounds

Although most of the Georgia continental shelf is covered with Pleistocene and Holocene unconsolidated
sands, consolidated carbonate rocks crop out across the entire width of the shelf from a depth of 30 feet
out to the shelf edge. These outcrops are referred to as hard grounds, hard-bottoms, or live-bottoms, and
form unique, stable substrate for marine communities. More than 100 such hard grounds have been
identified on the Georgia continental shelf. Hard grounds are "hotspots" of biological diversity on the
continental shelf and provide natural habitat for many commercially and recreationally important fish
species including black sea bass, porgies, snapper, and groupers and habitat for some species of shrimp.
The hard grounds also provide habitat for endangered species of sea turtles.

1.3 Mineral Resources

Exploration or development of oil and gas on the Georgia continental shelf must consider the presence of
other mineral resources on the shelf including phosphates, gas hydrates, and heavy mineral sands. Studies
in the late 1980's and early 1990's suggest that there may be 21 billion tons of phosphatic rock within 60
miles of the Georgia shoreline. Studies of offshore surficial sediments suggest that, although the heavy
mineral resource potential of the Georgia continental shelf is limited, there may be titanium-bearing
placer deposits offshore of the Altamaha River. Extensive gas hydrates have been discovered on the
continental slope off Georgia. These gas hydrates represent both a significant resource and a geologic
hazard. The hydrates could produce instability in sediments, creating engineering problems for oil and gas
exploration and development.

1.4 Beaches
Georgia’s coastal sand dunes, beaches, sandbars, and shoals comprise a vital natural resource system
known as the sand-sharing system. This resource acts as a buffer to protect real and personal property
and natural resources from the damaging effects of floods, winds, tides, and erosion. Georgia’s offshore
sandbars and shoals are the system's first line of defense, helping to protect the onshore segment of the
system by acting as reservoirs of sand for the beaches. In addition, sandbars, beaches, and sand dunes
provide habitat opportunities for a range of wildlife. Lastly, Georgia’s beaches provide an unparalleled

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natural recreation resource which has become vitally linked to the economy of Georgia's coastal zone and
to that of the entire state.

This natural resource system is costly, if not impossible, to reconstruct or rehabilitate once adversely
affected by human activities and is important to conserve for present and future use and enjoyment of all
citizens and visitors to this state. Further, the sand-sharing system is an integral part of Georgia's barrier
islands, providing great protection to the state's marshlands and estuaries. Exploration or development
of oil and gas along Georgia’s coast must consider and ensure against unreasonable impacts that may
interfere with the habitat values, storm protection, and recreational opportunities which are vital to the
State of Georgia.

Barrier island beaches are particularly vulnerable to the effects of an oil spill as our Gulf Coast neighbors
learned in 2010. While an extraordinary event, the impact of the BP oil spill on Gulf beaches is still being
quantified. Obvious impacts were to recreation and tourism industries. The spill resulted in 9,500 beach
closures, or “oil spill advisory days”, over the next year that were felt in 4 states (NRDC, 2011). After the
clean-up, oil residue diminished over time but was still present on some beaches in 2014. The sand-oil
amalgamations that formed as balls (tar balls) on beaches were denser than water and did not float away.
The tar balls continued to cause beach re-oiling three years after initial spill as they were uncovered and
transported during storms. Gulf Coast beaches also found that the oil removal process itself had
unintended consequences: the deep cleaning altered shell-to-sand grain size ratios that affected habitats
and sediments dynamics (erosion and accretion) of the beaches (U.S. vs. BP Exploration & Production, Inc.
et al., 2014).

1.5 Coastal Marshlands

Behind Georgia’s 14 barrier islands exist over 368,000 acres of relatively pristine coastal salt marshes
which are inhabited by many commercial and recreational fisheries and act as buffers against storm surge
and sea-level rise. Marshlands provide important ecosystem services including bank and shoreline
protection, habitat for commercial and recreational species, carbon sequestration, and sediment and
particulate retention.

Smooth cordgrass, Spartina alterniflora, is the dominant plant found in Georgia’s salt marshes. Spartina
marshlands serve as a foundation for the complex food web that supports many of our commercial and
recreational fisheries species. Salt marshes are the first line of defense against storm surge, including
those that are hurricane induced. Economic valuations have found the average annual value of marshes
for hurricane protection is approximately $996 per hectare (Costanza, et al., 2008). In Georgia, this
translates to nearly $15 million annually in storm surge protection.

Coastal marshlands are highly sensitive to oil spills which can result in complete vegetation mortality,
substantial reduction in species and abundance, and significant shoreline erosion. Exacerbated erosion
caused by loss of marsh vegetation, leads to the loss of important salt marsh habitat and threatens coastal
communities and waterfront property owners. Oil spills are shown to decrease biomass of Spartina
alterniflora and increase shoreline erosion rates by more than 50% in the Gulf of Mexico where tidal
amplitudes are much smaller than Georgia. After the BP Deepwater Horizon oil spill of 2010, one study
determined “oil-driven plant death on the edges of these marshes more than doubled rates of shoreline
erosion, further driving marsh platform loss that is likely to be permanent” (Sillliman et al., 2012). Other
studies have shown that oil spills result in more than a 50% increase in the rate of coastal wetland
shoreline land loss for the 3-6 years post spill (Beland et al., 2017).

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Oil type is one of the major factors determining the degree and type of impacts on marshes. Lighter oils
are more acutely toxic than heavier oils; however, when spilled offshore, light oils seldom cause extensive
damage because they spread into thin slicks. Heavy refined oils and most crude oils affect marshes
through physical smothering of both leaves and soils. The oil weathering and emulsification prior to
landfall reduces the initial toxicity of the oil. The extent of oiling on the vegetation is a key factor. If only
parts of the leaves are oiled, often the marshes recover within one growing season. Louisiana marshes
affected by the BP Horizon spill, however, did not begin recovering until 2.5 years post-spill. Exposure to
waves and currents that speed oil removal is another key factor. Other factors include degree of
contamination of the soils, time of year, and different sensitivities among plant species (Michel and
Rutherford, 2013).

Over the past 28 years, researchers using satellite imagery found that salt marshes along the Georgia coast
have declined in aboveground biomass by 33-39% due to increases in drought frequency and severity
(O’Donnell and Schalles, 2016). This loss could be exacerbated with an oil spill. Undoubtedly, Georgia’s
coastal marshlands softened the impacts of recent coastal storms, although Hurricane Irma is still
expected to cost the federal government over $120 million in individual and household program, flood
insurance and public assistance grants (FEMA, 2017). If Georgia’s marshes are further degraded due to
oil spill impacts and cannot absorb as much wave energy or storm surge, the public cost of coastal storms
will rise sharply.

1.6 Offshore Currents

The Gulf Stream is a warm and swift current that originates in the Gulf of Mexico, stretches around the
eastern coastline of the United States, and passes about 70 miles off the coast of Georgia. It travels along
the outer edge of the continental shelf and does not enter the shelf itself, but Gulf Stream effects
(meanders, tendrils, upwelling), wind forcing, tidal effects, bathymetric effects and fronts can move
waters onshore (South Atlantic Sea Grant, 2010).

2.0 Biological Environment

2.1 Marine Mammals
One species of manatee, 7 species of baleen whales and at least 22 species of toothed whales and dolphins
occur in the South Atlantic Planning Area. Of these, 6 species are listed as threatened or endangered under
the Endangered Species Act (ESA): blue whale (Bolaenoptera musculus), fin whale (Balaenoptera
physalus), North Atlantic right whale (Eubalaena glacialis), sei whale (Balaenoptera borealis), sperm whale
(Physeter macrocephalus) and West Indian manatee (Trichecus manatus). Three of these species also
occur in Georgia state waters and are listed as endangered under the Georgia Endangered Wildlife Act:
humpback whale, North Atlantic right whale and West Indian manatee. Potential lethal impacts to marine
mammals from oil and gas exploration and development include vessel strikes, entanglement in debris,
ingestion of debris and oil, and sound from high-energy active acoustic sources (e.g., airguns used for
seismic surveys). Harassment and habitat degradation may result from vessel movements, low altitude
aerial overflights, geophysical and geotechnical surveys, construction and extraction activities, and oil
spills. While all marine mammal species could be affected by these activities, North Atlantic right whales
and West Indian manatee are the species of greatest concern in Georgia state waters and adjacent federal
waters.

2.1.1 North Atlantic Right Whale

The North Atlantic right whale is among the most endangered whale species with a population numbering
approximately 450 whales. Waters along the Southeast U.S. coast are the primary wintering ground and
only known calving ground for the species. Protection of the whales and their calving habitat is critical to

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the species' recovery. Spatially, right whales are most frequently found in waters 30-80 feet deep within
15 mi of the South Carolina, Georgia and northeast Florida coastline. Temporally, right whales are present
from November to April annually. Little survey effort has been conducted for right whales >34 mi from
shore, so the extent to which right whales may inhabit deeper waters along the continental shelf and
waters east of the shelf break is uncertain.

Vessel collisions and entanglement in fishing gear are the primary causes of right whale mortality. Other
threats include habitat degradation, anthropogenic sound sources, contaminants and climate change.
Whenever practical, activities with the potential to impact right whales should be conducted at locations
and times that right whales are not present. Activities that must occur when right whales are present, or
activities that impact right whale habitat, should be adequately mitigated to minimize impacts.

Additional data on right whale distribution and abundance are needed to assess potential impact of oil
and gas exploration along the North Carolina coast, Mid-Atlantic coast, and at locations >34 mi east of the
South Carolina, Georgia and northeast Florida coast. If oil and gas exploration and development leads to
increased vessel traffic, debris and noise within 34 mi of shore, right whales could be impacted
accordingly. An oil spill during the calving season could have species-level consequences because
Southeast U.S. waters are the only calving grounds for the species, calving females remain on the calving
grounds for 2-3 months, there are only approximately 100 calving females, and over 30% of calving
females can be found on the calving grounds during some years.

2.1.2 West Indian Manatee

West Indian Manatees are threatened with over 6,000 animals inhabiting coastal and riverine habitats in
the Southeast U.S, primarily in peninsular Florida. Each spring and summer an unknown number of
manatees migrate north into coastal Georgia and the Carolinas. They feed on marsh grass and other
vegetation, primarily in estuarine and riverine habitats, although they venture into ocean waters,
particularly during migration. The maximum distance manatees travel into Atlantic Ocean waters is
unknown, but movements >3 mi from shore are probably rare. Manatees prefer water temperatures
above 68°F and must migrate south back to Florida each fall as water temperatures cool. Vessel collision,
fishery entanglements, crushing in water control structures and habitat degradation are the primary
anthropogenic impacts to manatees. It is unlikely that manatees would be impacted directly by normal
offshore oil and gas exploration and development activities, but they could be impacted by increased
vessel traffic and construction at shore-side facilities. Oil spills could negatively impact manatees and their
coastal habitats.

2.2 Sea Turtles

Five species of sea turtles occur in Georgia's coastal waters year-round including the loggerhead, Kemp's
ridley, green, leatherback and hawksbill. All five species are listed under the Federal Endangered Species
Act as threatened or endangered and under Georgia's Endangered Wildlife Act. Anthropogenic activities
resulting in harassment (disruption of foraging activity) and/or habitat degradation include construction
activities, increased vessel traffic, habitat contamination, and oil spills. Potential lethal effects of oil and
gas exploration and development activities on sea turtles include vessels strikes, entanglements in debris,
ingestion of oil or debris (particularly juveniles using sargassum weed lines), nest loss due to oil
contamination and sound from high-energy acoustic sources.

2.2.1 Juvenile Foraging Aggregations

The composition and abundance of sea turtles varies seasonally based on water temperature and
migratory patterns. The shallow continental shelf waters off the Georgia coast are important

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developmental foraging habitat for juvenile loggerhead, Kemp's Ridley, and green sea turtles. Juvenile sea
turtles are commonly found in the estuaries and offshore waters foraging on crabs and other invertebrate
species. In-water trawl surveys conducted by South Carolina DNR suggest that juvenile foraging sea turtle
abundance in the nearshore waters of Georgia is higher than coastal waters of South Carolina, and the
southern portion of the North Carolina coast. Loggerheads are the most common species foraging in
coastal waters followed by Kemp's ridley and green turtles. Juvenile sea turtles are generally less abundant
in winter when they move offshore to warmer waters near the edge of the Gulf Stream. Post-hatchling
sea turtles are commonly found in sargassum weed lines found off Georgia out to the Gulf Stream. Juvenile
hawksbill turtles are generally associated with coral reef habitat and are rare in Georgia's coastal waters.

2.2.2 Leatherback Sea Turtle

Leatherback turtles are found in Georgia's coastal waters during the winter months foraging on jellyfish.
High leatherback densities have been documented within 30 miles of shore during right whale aerial
surveys conducted from mid-December through the end of March. Leatherback densities are also known
to be high in late spring (April-May) from strandings and dedicated leatherback aerial surveys conducted
by Georgia DNR. Leatherbacks seen during late spring are presumed to be migrating along the Georgia
coast on their way to feed in the north Atlantic during the summer. Adult leatherbacks are found nesting
on Georgia beaches in the spring and summer although nesting densities are generally low with less than
10 nests statewide annually.

2.2.3 Loggerhead Sea Turtle

Loggerhead turtles are abundant along the Georgia coast during the nesting season (April through
August). During the inter-nesting period, adult loggerheads are concentrated within 3 miles of shore.
Loggerheads nest an average of 4.5 times per season on a 9-13 day cycle. Loggerhead turtles are relatively
sedentary during the inter-nesting period while they prepare for each nesting cycle (ovulate and shell
eggs, return to nesting beach). Hatchling loggerheads disperse from nesting beaches and are found in
offshore convergence zones associated with sargassum weed lines.

2.3 Birds
2.3.1 Beach Nesting Birds
Approximately 12 species of birds nest on the beaches and dunes in coastal Georgia. Five state listed
species nest on our beaches. These species are Wilson's Plover (Charadrius wilsonia), American
Oystercatcher (Haematopus palliatus), Gull-billed Tern (Geochelidon nilotica), Black Skimmer (Rynchops
niger) and Least Tern (Sternula antillarum). These species are protected by the Georgia Endangered
Wildlife Act. Other beach nesting birds of concern include Brown Pelican (Pelecanus occidentalis), Royal
Tern (Thallasius maximus), Sandwich Tern (Thallasius sandvicensis), and Laughing Gull (Leucophaeus
atricilla). Direct impacts could include oiling and death, and the most damage would occur at colonial
seabird colonies where up to six thousand nesting pairs can occur. Impacts could include direct oiling of
nesting sites, as well as oiling of foraging areas and indirect impacts to prey populations.

2.3.2 Saltmarsh Nesting Birds

Approximately 12 species of birds nest low in saltmarsh vegetation, or along the ground on the edges of
saltmarsh. Two of these species are listed in the Georgia State Wildlife Action Plan (SWAP) as species of
conservation concern. These species are Least Bittern (lxobrychus exilis) and Tricolored heron (Egretta
tricolor). Two additional species represent subspecies that are range-limited to the southeastern United
States, including the Seaside Sparrow (Ammodramus maritimus macgillivrai) and Worthington's Marsh
Wren (Cistothorus palustris griseus). Several other species that can nest low in saltmarsh vegetation
include Clapper Rail (Rallus longirostris), White Ibis (Eudocimus albus), Glossy Ibis (Plegadis falcinellus),

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Snowy Egret (Egretta thula), and Little Blue Heron (Egretta caerulea). The Saltmarsh Sparrow
(Ammodramus caudacutus) is a rapidly declining species that winters on the Georgia coast in saltmarsh
habitat and is a SWAP listed species. It is currently under review by USFWS to determine if it merits listing
under the Endangered Species Act due to annual 9% declines. For these species any spill would potentially
impact nesting colonies and/or foraging sites. The construction of any supporting infrastructure through
the marsh would clearly impact many of these species.

2.3.3 Coastal Foraging Species

Many species from several taxa forage along our shores and marshes and would be impacted by any spill.
There are approximately 17 species of shorebirds and 14 species of wading birds that regularly use our
coastal habitats. The federally listed Piping Plover (Charadrius melodus) forages along much of the Georgia
coast in all seasons except summer. The state hosts more that 30% of the critically endangered Great
Lakes subspecies of Piping Plover (C. m. circumcinctus). The Federally listed Wood Stork (Mycteria
americana) regularly forages in the intertidal marshes along our coast, particularly in the vicinity of coastal
breeding colonies. Roughly 1,000 pairs of Wood Stork (half of the state’s nesting population) nest within
a short foraging flight of the intertidal zone. The Federally listed Red Knot (Calidris canutus rufa) also
forages in large numbers along our outer beaches in fall, winter and spring. Over 50% of the population
of rufa knots were documented on the Georgia coast during a single fall migration, making this the only
known fall staging area for the subspecies. Other SWAP listed species that would be impacted by any spill
along our beaches and marshes include Marbled Godwit (Limos fedoa), Whimbrel (Numenius phaeopus)
and Bald Eagle (Haliaeetus leucochephalus). A number of other species of migratory shorebirds would also
be potentially impacted with any spill in their foraging and roosting areas. Many of our beach
nesting/foraging birds depend on low-lying near-shore sand bars and spits for nesting, and intertidal flats
for foraging.

2.3.4 Pelagic Species

A number of species winter or are passage migrants in the near-shore and off-shore environments. There
are potential impacts of unknown magnitude to these species with the construction of off-shore
infrastructure and associated lighting. Large numbers of Northern Gannet (Morus bassanus), Common
Loon (Gavia immer), and a variety of seaducks [primarily Black Seater (Melanitta nigra) and Lesser Scaup
(Aythya maria)] winter in waters adjacent to Georgia. There is the potential for feeding habitat
displacement of wintering waterfowl if multiple structures are placed in fairly shallow water where diving
ducks forage. Many other species occur in lower numbers further off-shore, including several Procellarids
(shearwater and petrel) Hydrobatids (storm petrel) and Scolopacids (phalarope).

2.4 Marine Fishes

2.4.1 Shortnose Sturgeon
The Shortnose Sturgeon, (Acipenser brevirostrum) occur in nearly every major river system along the U.S.
eastern seaboard and range from the St. John River in New Brunswick, Canada to the St. Johns River,
Florida. It was exploited throughout its range until the 1950's and has been listed as endangered
throughout its range since March 11, 1967. Shortnose inhabit slow moving riverine waters or nearshore
marine waters, and migrating periodically into faster moving fresh water areas to spawn. In Georgia, they
have been documented in Altamaha, Ogeechee, and Savannah Rivers. Threats include construction of
dams resulting in loss of suitable habitat, pollution of northeastern river systems, habitat alterations from
discharges, dredging or disposal of material into rivers, and related development activities involving
estuarine/ riverine mudflats and marshes (NOAA, 2014).

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2.4.2 Atlantic Sturgeon
The Atlantic Sturgeon (Acipenser oxyrinchus) is a long-lived (60 years}, estuarine dependent, anadromous
species. Adults spawn in freshwater in the spring and early summer and spend most of their lives in
estuarine and marine waters, at depths of 10-50 m, on gravel and sand substrates. Atlantic sturgeon were
historically present in 38 U.S. rivers from St. Croix, ME to the Saint Johns River, FL. Presently the species
is present in 32 of these rivers, and spawning in 20 of them. The Altamaha River (GA) has one of the
healthiest and most stable populations on the East Coast. Overfishing from the 1950's through 1990's
have reduced the populations of this long-lived species, resulting in a harvest moratorium in 1998, and a
ESA listing of endangered for all distinct population segments, including the South Atlantic, by 2012
(NOAA, 2014).

2.4.3 Finfish
Georgia waters are home to an abundance of species of finfish, including red drum, spotted seatrout,
flounder species, and southern kingfish (whiting). Over 50 species of offshore finfish, including snapper,
grouper, dolphin, wahoo, and porgies, are cooperatively managed by DNR and the South Atlantic Fisheries
Management Council. Many species also migrate inshore and offshore of the GA coast such as cobia and
tripletail. Artificial reefs (inshore and offshore) are placed to support habitat for these ecologically
important species.

Many resident finfish species are susceptible to adverse impacts from oil spills as well. Many of these
species have a strong site fidelity (snapper and grouper) but can be displaced by the noise associated with
seismic surveys. The sounds produced from such surveys can disrupt feeding, spawning, and displace
fishes to less desirable habitats. Eggs and larvae can be adversely impacted by sedimentation and
turbidity associated drilling operations (SAFMC, 2015).

In a study on the effects of polycyclic aromatic hydrocarbons (PAHs) (specifically naphthalene and
phenanthrene) on finfish, it was found that red drum Sciaenops ocellatus and southern flounder
Paralichthys lethostigma were more susceptible to adverse effects of oil spills due to low bio-
transformation rates of PAHs (Pulster et al., 2017). PAHs released from oil spills such as the Deepwater
Horizon can still exert toxicity when combined with UV weathering to speckled seatrout Cynoscion
nebulosus and red drum (Alloy et al., 2017). Some of the sublethal effects from weathered oil spills that
have been observed in red drum larvae ranged from reduced nervous system development to unusual
cardiac morphology (Xu et al., 2015). Even processes involved with oil spill cleanups can negatively affect
all levels of the estuarine food web. Shoreline cleaners such as PES-51, CytoSol, and Accell Clean SWA
used during oil spills can exhibit toxic effects such as reduced growth in invertebrates, mortality in finfish
and invertebrates, and increased bacterial densities and low dissolved oxygen (Delorenzo et al., 2017).

2.4.4 Shrimp
White shrimp are found at depths of 20 to 295 feet. Brown shrimp are most abundant in water depths of
89 to 177 feet, but may occur in commercial quantities in water depths as great as 361 feet. Pink shrimp
are most abundant in water depths of 36 to 118 feet. Rock shrimp are most abundant at depths of 111 to
180 feet. Royal red shrimp are most common at depths of 840 to 1,800 feet.

White, brown, and pick shrimp may not be directly influenced by seismic surveys and energy development
projects given their proximity to the coast. Rock and royal red shrimp are found in deeper waters where
energy development is most likely. There is a high likelihood of increased sedimentation, turbidity, egg
and larvae mortality associated with energy development. All shrimp species may suffer from soft tissue

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damage (such as gills) because of turbidity. Increased turbidity may displace food sources and adversely
impact larval development by interfering with proper molting and growth.

2.4.5 Shellfish
Georgia waters support many natural species of shellfish including mussels, clams, and oysters which can
be found in estuaries and marshlands throughout the coast. Shellfish are vital for the health of aquatic
ecosystems and are essential fish habitat and shelter for a number of other living organisms. They filter
pollutants from water, stabilize estuarine shorelines, and are fished both recreationally and commercially.
The native eastern oyster (Crassostrea virginica) was once abundant in Georgia until overfishing in the
early 1900s decimated the population by as much as 80 percent. Today, efforts are underway to restore
oyster reefs in Georgia.

Oil spills can threaten Georgia’s existing wild oyster and clam stocks by killing off food supplies and
significantly reducing reproductive rates. Studies following the BP oil spill in the Gulf Coast suggested that
oil remnants in living oysters could return to pre-spill levels in as little as six months.

2.5 Protected Habitats

2.5.1 Offshore Artificial Reefs
Georgia DNR maintains 30 offshore artificial reefs ranging from 3 to 70 miles from the coast. Each reef is
a defined area (typically 4 mi2) and is designated as such on all federal navigational charts. The purpose
of this reef system is to create habitat by placing structure (ships, concrete, pre-fab devices, etc.) on flat
barren sand bottoms. Fouling organisms quickly colonize the materials, which are followed by
invertebrates, forage fishes, and large predatory and game fishes. These new ecosystems enhance fish
production and create additional recreational fishing and diving opportunities.

The South Atlantic Fishery Management Council (SAMFC) has designated 19 of these reefs as Special
Management Zones and Essential Fish Habitat – Habitat Areas of Particular Concern. These are considered
high priority areas for conservation, management, or research because these habitats are rare, sensitive,
stressed by development, or important to ecosystem function (NOAA, 2007). Potential impacts to these
habitats from oil and gas exploration and development may include: impacts to fish populations
associated with seismic surveys (displacement, disruption of spawning activity, death); and potential
sediment movement and physical disturbance associated with drill activities, such as increased turbidity,
smothering fouling organisms and disrupting trophic connectivity (SAFMC, 2015).

2.5.2 Inshore Artificial Reefs

Georgia’s 15 inshore artificial reefs have been constructed in tidal creeks and rivers to mitigate
development efforts in response to coastal expansion and a rapidly growing inshore recreational fishery.
All 15 inshore reefs were created in estuaries to enhance fisheries resources in areas lacking suitable
habitat and to provide an increase of accessible habitat to coastal anglers. The placement of structures in
the intertidal zone also increases the potential for oyster recruitment and shoreline stabilization. It is
highly unlikely oil and gas exploration and production will take place in the estuaries where these reefs
are located. However, several potential impacts to these habitats remain: sedimentation, drilling muds,
and petroleum products could be transported into the estuary, smothering fouling organisms and shellfish
that provide the living infrastructure for these inshore reefs; and transport cables or pipes in support of
offshore sites traversing near a reef site could damage the structures and displace recreational fishes
(SAFMC, 2015).

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2.5.3 Gray's Reef
Gray's Reef is one of the largest live bottom/hard ground areas on the southeastern continental shelf. In
January 1981 Gray's Reef was designated as a National Marine Sanctuary. The Sanctuary is located 17.5
miles east of Sapelo Island and comprises 17 square nautical miles of sea-floor. Gray's reef contains
extensive, discontinuous outcroppings of Pliocene-age limestone, which provide a substrate for the
attachment of algae, sponges, barnacles, sea fans, hard coral, and bryozoa. Other important invertebrates
on the reef include sea stars, crabs, lobsters, gastropods, and shrimp. The diverse physical environments
on the reef and the invertebrate fauna attract numerous species of fish including black sea bass, snapper,
grouper, and mackerel. Loggerhead sea turtles use the reef for feeding and resting. A Presidential
Directive, issued in 1998, permanently withdrew all areas of the outer continental shelf within existing
marine sanctuaries (specifically including Gray's Reef) from oil and gas leasing.

2.5.4 Cumberland Island National Seashore

Cumberland Island is the southernmost barrier island along the Georgia coast. Congress established the
Cumberland Island National Seashore as a unit of the National Park System in October 1972. Cumberland
Island is 17.5 miles long and 36,415 acres in area, including 16,850 acres of marsh, mud flats, and tidal
creeks. The northern half of the island was designated as a wilderness or potential wilderness area in
1982. In 2004, the island had 42,265 recreational visitors.

2.5.5 Right Whale Critical Habitat

A portion of the Southeast U.S. coastal waters from approximately Cape Canaveral, FL to Wilmington, NC
is designated as critical calving habitat for North Atlantic right whales (50 CFR 226.203). All Georgia state
and federal waters from the Georgia shoreline and eastward approximately 34-37 mi from shore are
designated as critical calving habitat.

2.5.6 Loggerhead Sea Turtle Critical Habitat

A portion of the Georgia coast is currently designated as loggerhead sea turtle critical habitat. The
designated habitat includes coastal waters from the beach out to one nautical mile seaward of important
nesting beaches including Little Tybee, Wassaw, Ossabaw, St Catherines, Blackbeard, Sapelo, Little
Cumberland, and Cumberland Islands. In addition, critical habitat is designated for areas off the Georgia
coast from the western edge of the Gulf Stream to the eastern boarder of the EEZ where sargassum weed
occurs. Oil and gas exploration and development projects have the potential to disrupt critical habitat
through construction activities, increased vessel traffic, habitat contamination, and oil spills

2.5.7 Piping Plover Critical Habitat

The National Fish and Wildlife Service designated 16 distinct areas of the Georgia coast as critical habitat
for migrant and overwintering Piping Plover. This includes the federally endangered Great Lakes breeding
population which consists of >100 nesting pairs, and the Federally Threatened Atlantic breeding
population which consists of roughly 2,000 pairs.

2.5.8 Other Protected Coastal Areas

Other Protected areas on the Georgia coast include the following:
Tybee National Wildlife Refuge
Wassaw National Wildlife Refuge
Harris Neck National Wildlife Refuge
Blackbeard Island National Wildlife Refuge and Wilderness Area
Wolf Island National Wildlife Refuge and Wilderness Area
Ossabaw Island Heritage Preserve

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 Sapelo Island National Estuarine Sanctuary
Jekyll Island State Park
Little Tybee/Cabbage Island Natural Area
Designated Bird Islands

3.0 Socio-Economic
3.1 Commercial Jellyfish Fishery
The Cannonball jellyfish (Stomolophus meleagris) represents one of Georgia’s largest fisheries by volume
(weight), however, due to confidentiality concerns catch statistics cannot be published. In 2016, seven
vessels made 68 fishing trips to harvest jellyfish in state and federal waters off Georgia. Seismic surveys
will likely have an impact on these soft-bodied organisms given their limit mobility. Sedimentation
associated with drilling activities may be detrimental to zooplankton food sources as well as survivability
of cannonball jellyfish eggs and larvae.

3.2 Commercial Shrimp Fishery

Food shrimp is the most valuable fishery in Georgia, while bait shrimp is 4th. In 2016, shrimpers landed
2,147,720 pounds of food shrimp worth $9,161,651, and 54,637 pounds of bait shrimp, worth $767,848.
Georgia issued licenses to 261 commercial shrimp trawlers in 2016. Species taken (in order of volume)
include white shrimp (Litopenaeus setiferus), brown shrimp (Farfantepenaeus aztecus), rock shrimp
(Sicyonia brevirotris), pink shrimp (Farfantepenaeus duorarum), and royal red shrimp (Hymenopenaeus
robustus).

3.3 Commercial Finfish Fisheries

In 2016, the commercial finfish catch in Georgia was 529,471 pounds, worth $367,843. Finfish landings
were dominated by the snapper/grouper management complex of fishes, which includes sea basses,
snappers, groupers, jacks, tilefish, porgies, grunts, triggerfishes, wrasses, spadefish, and wreckfish.

3.4 Recreational Fishing

Recreational saltwater fishing is an important component of the Georgia coastal economy. Areas with
hard structures are essential sites for marine recreational fishing. 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. The National
Marine Fisheries Service (NMFS) estimates that Georgia recreational anglers landed more than 1.4 million
pounds of marine fish in 2016. This NMFS survey also estimates that there were 198,345 resident
saltwater anglers in 2016. Recreational species that may be directly impacted by offshore energy
exploration and development include summer flounder, bluefish, numerous snapper and grouper species,
black sea bass, king and Spanish mackerel, and cobia (SAFMC, 2015).

3.5 Commercial and Recreational Shellfish Fishery

In 2016, commercial shellfish landings totaled 385,079 pounds of shellfish meats valued at $2,634,125. Of
that total, hard clams accounted for the majority with 349,037 pounds valued at $2,407,111 and oysters
totaled 36,042 pounds valued at $227,014. In 2016, the shellfish fishery employed over 100 harvesters
and is slowly transitioning from a wild fishery to a more aquaculture based industry. Currently,
approximately 31,000 acres are permitted to be harvested commercially along the coast. Hard clam
farming is currently sustaining the bulk of the fishery with hopes that oyster aquaculture will also become
a viable option. Unlike clam farming, oyster farming involves a significant investment in gear and seed.
Recreational shell fishing is also gaining in popularity and is only permissible in designated public shell

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fishing areas along the coast. There is a total of seven public harvest areas totaling 8,500 acres that are
managed exclusively for recreational harvest.

Georgia follows federal Food and Drug Administration procedures for the closure of commercial and
recreational shellfish harvesting following an oil spill in coastal waters. The fishery may not re-open until
shellfish meats have been tested for and free from oil residue.

3.6 Ports
The Georgia Ports Authority owns and operates deepwater ports in Savannah and Brunswick, Georgia.
The Port of Savannah is the fourth largest container port by volume in the United States and handled more
than 10 percent of all U.S. containerized exports in Fiscal Year (FY) 17. The Port moved 33.4 million tons
of cargo across all terminals in FY17. The Port of Brunswick is the second busiest roll on/roll off port in
the United States. Together and including two inland barge terminals, Georgia ports annually support
more than 370,000 jobs throughout the state and contribute $20.4 billion in income, $84.1 billion in
revenue and $2.3 billion in state and local taxes to Georgia’s economy.

3.7 Tourism
Coastal eco-tourism is a fast-growing segment of Georgia’s $60.8 billion tourism industry. Supporting
more than 450,200 jobs and generating $3.1 billion in taxes state-wide in 2016, tourists enjoy the beaches
and coastal marshlands nearly year around (GEcD, 2018). A substantial oil spill could devastate outdoor
recreation and tourist opportunities on Georgia’s beaches for years.

4.0 Site Selection Tools

4.1 Georgia Coastal and Marine Planner (GCAMP)
The Georgia Department of Natural Resources Coastal Resources Division partnered with the Georgia
Institute of Technology to develop and implement the Georgia Coastal and Marine Planner, an online
mapper that consolidates existing state and federal data sets for the purposes of managing coastal and
ocean activities. The GCAMP viewer currently holds over 70 datasets focused on the biological resources,
physical characteristics, and human (recreational, commercial, legislative) activities for state and federal
offshore waters. Currently under development are data layers that reflect recreational usage of the
project area (fishing, boating, eco-tours, etc.). GCAMP is a site selection and evaluation tool for coastal
and offshore activities. GCAMP web address: http://geospatial.gatech.edu/GCAMP/.

5.0 Resources Cited

Alloy, M., Garner, T.R., Bridges, K., Mansfield, C., Carney, M., Forth, H., Krasnec, M., Lay, C., Takeshita, R.,
Morris, J., Bonnot, S., Oris, J., and A. Roberts. 2017. Co-exposure to sunlight enhances the toxicity of
naturally weathered Deepwater Horizon oil to early lifestage red drum Sciaenops ocellatus and speckled
seatrout Cynoscion nebulosus. Environmental Toxicology and Chemistry. 36:780-785.

Beland M, Biggs TW, Roberts DA, Peterson SH, Kokaly RF, Piazza S. 2017. Oiling accelerates loss of salt
marshes, southeastern Louisiana. PLoS ONE 12(8): e0181197.

Costanza, R., Pe´ rez-Maqueo, O., Martinez, M.L., Sutton, P., Anderson, S.J., Mulder, K., 2008. The value
of coastal wetlands for hurricane protection. AMBIO: J. Hum. Environ. 37, 241–248.

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DeLorenzo, M.E., Key, P.B., Wirth, E.F., Pennington, P.L., Chung, K.W., Pisarski, E., Shaddrix, B., Baxter, S.,
and M.H. Fulton. 2017. Efficacy and ecotoxicological effects of shoreline cleaners in salt marsh
ecosystems. NOAA Technical Memorandum NOS NCCOS 232. 110pp.

Federal Emergency Management Agency (FEMA). December 14, 2017. Assistance to Georgians Tops $65
Million to Help Recovery Efforts. Retrieved from: https://www.fema.gov/news-
release/2017/12/14/assistance-georgians-tops-65-million-help-recovery-efforts.

Georgia Department of Economic Development. February 21, 2018. Retrieved from

http://www.georgia.org/industries/georgia-tourism/.

Georgia Ports Authority. February 5, 2018. Retrieved from

http://gaports.com/media/press-releases/artmid/3569/articleid/161/gpa-10m-teu-capacity-in-10-years.

Michel, J., Rutherford N. 2013. Oils Spills in Marshes: Planning and Response Considerations. NOAA
National Ocean Service Office of Response and Restoration and American Petroleum Institute, 126pp.

NOAA. 2007. Magnuson-Stevens Fishery Conservation and Management Act (Public Law 94-265).
Washington (DC): NOAA. 6 p.

NOAA Fisheries, Office of Protected Species-Atlantic Sturgeon. August 19, 2014. Retrieved from
https://www.nefsc.noaa.gov/sos/spsyn/af/sturgeon/

NOAA Fisheries, Office of Protected Species-Shortnose Sturgeon. August 19, 2014. Retrieved from
https://www.nefsc.noaa.gov/sos/spsyn/af/sturgeon/

NRDC (Natural Resource Defense Council). 2011. Beach closures, advisories, and notices due to the BP oil
disaster. Testing the waters: A guide to water quality at vacation beaches. Retrieved from
https://www.nrdc.org/water/oceans/ttw/gulf.pdf.

O’Donnell, J.P.R., Schalles, J.F. 2016. Examination of abiotic drivers and their influence on Spartina
alterniflora biomass over a twenty eight year period using Landsat 5 TM satellite imagery of the Central
Georgia Coast. Remote Sensing, 8, 477.

Pulster, E.L., Main, K., Wetzel, D., and S. Murawski. 2017. Species-specific metabolism of naphthalene
and phenanthrene in 3 species of marine teleosts exposed to Deepwater Horizon crude oil. Environmental
Toxicology and Chemistry. 36:3168-3176.

SAFMC. 2015. Policy for the protection and restoration of essential fish habitats from energy exploration
and development. (December 14, 2015).
http://cdn1.safmc.net/wp-content/uploads/2016/11/28102846/SAFMCEnergyPolicyDec1415.pdf

Silliman, B.R., Kopel, J., McCoy, M.W., Diller, J., Kasozi, G.N., Kamala, E., Adams, P.N., Zimmerman, A.R.
2012. Degradation and resilience in Louisiana salt marshes after the BP – Deepwater Horizon oil spill. Proc.
Natl. Acad. Sci. USA 109, 11234–11239.

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U.S. v. BP Exploration & Production, Inc. et al. 2014. Actual and Potential Harm from the Macondo Well
Blowout. Submitted on Behalf of the United States. Prepared by: Donald F. Boesch. Retrieved from
http://www.mdl2179trialdocs.com/releases/release201501200700000/TREX-013183.pdf.

South Atlantic Sea Grant. 2010. Oil Spill Physical Oceanography Summit June 9, 2010 - Skidaway Institute
of Oceanography, Savannah, Georgia. Georgia Coastal Research Council Meeting Summary.

Xu, E.G., Khurigara, A.J., Magnuson, J., Hazard, E.S., Hardiman, G., Esbaugh, A.J., Roberts, A.P., and D.
Schlenk. 2017. Larval red drum (Sciaenops ocellatus) sublethal exposure to weathered Deepwater
Horizon crude oil: developmental and transcriptomic consequences. Environmental Science and
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