Stop approval of Walter Oil's Ewing Bank 966 exploration well
GN3800810274PublicPlan
Bureau of Ocean Energy Management· federal offshore waters, Outer Continental ShelfRegulations.gov comment docket ↗
Regulations.govWe track this on the agency’s own system of record, where most on-the-ground decisions live.
BOEM is set to approve a well with a worst-case uncontrolled blowout of 6,226,000 barrels of crude, 69 miles off Louisiana, based on an environmental review that considered no alternatives and consulted no outside agencies.
What’s at risk
The plan's own spill model shows Cameron Parish, home to three national wildlife refuges and habitat for numerous birds, finfish and endangered species, faces the highest probability of oil landfall within 30 days of any location analyzed. The plan lists dozens of threatened and endangered species, including a Rice's whale population of fewer than 100 individuals, sea turtles, and Gulf sturgeon, yet reports zero consultation with wildlife agencies and no ongoing environmental monitoring.
If this goes through
Approval authorizes drilling activity in the lease block from October 2026 through March 31, 2031, ramping from 78 days of operations in 2026 to 140 days per year from 2027 through 2030. The worst-case blowout and spill-response assumptions behind that multi-year authorization rest on an admitted data gap on bridge-over likelihood and an offset-well safety comparison the operator's own geologists say does not hold up at the depths of greatest risk.
Our plain-English read of the official notice ↗. Check it against the agency’s own words below.
By the numbers, from the agency’s own document
- Worst-case discharge for this well (EP)
- 62,260 bbls/day
- Total spill volume over 100-day relief well
- 6,226,000 bbls
- Regional OSRP WCD vs. this EP's WCD
- 432,298 bbl vs 62,260 bbl
- Distance from well to nearest shore
- 69 miles
- Distance to Rice's whale area, per EIA text
- over 130.5 miles
- Distance to Rice's whale area, per vicinity map
- ~234 statute miles
Attachment 15-A, Item 20.1
Open the document ↗“The Rice’s whale area is over 130.5 miles from the proposed operations.”
Each figure is checked word for word against the decision document ↗; open a label to read the sentence it comes from and the document it’s in.
The agency’s case, tested
What the agency argues, and whether its own record backs it
- 3
- Hold up
- 4
- No support given
- 2
- Never analyzed
Walter Oil & Gas Corporation asks the Bureau of Ocean Energy Management to approve one exploratory well at Ewing Bank Block 966. The well would sit in about 1,762 feet of water, 69 miles off Louisiana, and could be drilled any time through March 31, 2031. Its environmental impact analysis says effects are unlikely or minor because of distance from shore, a dynamically positioned rig that needs no anchors, and its regional oil spill response plan.
Effects
No support given
A significant oil spill from this well is unlikely.
Walter lists blowout safeguards: blowout preventer tests at least every three weeks, real-time flow and gas monitoring, two float barriers in the production casing, and pressure-while-drilling tools. It also cites BOEM's 2016 update of oil spill occurrence rates. But the only figure it actually gives is a Gulfwide volume ratio: from 2001 to 2015, one barrel spilled for every 1,624 produced, almost all of it from the Deepwater Horizon blowout. That isn't the chance of a blowout at an exploratory well, and it isn't tied to this site, where the hazards assessment assigns a moderate shallow water flow risk in two intervals. The worst case here is 62,260 barrels a day for 100 days.
The agency’s words, the record +Hide the words
The agency says
“However, based on data provided in the BOEM 2016 Update of Occurrence Rates for Offshore Oil Spills, it is unlikely that an accidental surface or subsurface spill of a significant volume would occur from the proposed operations.”
Water Quality
Elsewhere in the same document
“Between 2001 and 2015 OCS operations produced eight billion barrels of oil and spilled 0.062 percent of this oil, or one barrel for every 1,624 barrels produced.”
Water Quality
“Given this setting a Slight Risk of Gas and a Moderate Shallow Water Flow Risk is assigned.”
Attachment 3-D
Effects
No support given
Because a spill is unlikely, the well is 69 miles offshore and response equipment is available, no impacts to coastal wildlife refuges and wetlands are expected.
Walter says a spill is unlikely. It says its contracted equipment can be on site with enough capacity to recover oil and prevent land impact, to the maximum extent practicable, within an estimated 58 hours. It lists 149,223 barrels of derated offshore skimming capacity plus shoreline protection boom. Its own trajectory table, though, gives Cameron Parish a 7 percent and Plaquemines Parish a 5 percent conditional chance of being hit within 30 days. It names Cameron, which includes Sabine National Wildlife Refuge, as the most likely landfall. A response promised only to the maximum extent practicable doesn't support a flat expectation of no impacts.
The agency’s words, the record +Hide the words
The agency says
“Due to the distance from shore (69 miles) and the response capabilities that would be implemented, no impacts are expected.”
Coastal Wildlife Refuges
Elsewhere in the same document
“The BOEM OSRAM identifies the highest probability of impact to the shoreline of Cameron Parish within 30 days.”
Attachment 8-A
“Cameron Parish includes the east side of Sabine Lake, Sabine National Wildlife Refuge, Calcasieu Lake, Lacassine National Wildlife Refuge (inland) and Grand Lake.”
Attachment 8-A
Effects
No support given
Shipwreck sites won't be affected because the block isn't in a high-probability shipwreck area and the rig disturbs little seafloor.
The plan rests on more than the block designation. The rig is dynamically positioned and uses no anchors. The site-specific hazards letter says the one sonar contact, 538 feet west-northwest of the well, has no archaeological significance, and that the location is clear of man-made constraints within 2,000 feet. Walter also commits to stop work within a 1,000-foot radius and report to BOEM within 48 hours if it finds evidence of a shipwreck. One inconsistency remains. The archaeological report section uses template wording with several alternative designations, including an area where historic shipwrecks may exist. That doesn't fit the statement that the block isn't high probability for shipwrecks.
The agency’s words, the record and the law +Hide the words
The agency says
“Additionally, Ewing Bank Block 966 is not located in or adjacent to an OCS block designated by BOEM as having a high probability for occurrence of shipwrecks.”
Shipwreck Sites (known or potential)
Elsewhere in the same document
“The Echo Offshore archaeological report should be consulted regarding avoidances assigned to the various sonar contacts.”
Attachment 3-D
The law
“shall take into account the effect of the undertaking on any historic property.” National Historic Preservation Act, 54 U.S.C. 306108 ↗
Show 1 more claim +Show fewer
Science
No support given
The well's pore pressures and geology will match nearby offset wells, so their data can guide the well design and blowout prevention.
Walter says it designed the well using offset well and seismic data, and that it'll use measurement-while-drilling and pressure-while-drilling tools to read formation pressures as it drills. Its geology sections are withheld as proprietary. Walter's own shallow hazards consultant reached a different view for one interval. For Unit F, offset wells EW966-3 and 4, about 3,000 feet south, crossed that interval at a shallower level with different acoustic character, so the consultant says they aren't a direct analog. It assigns a moderate shallow water flow risk in Units F and G. That finding covers only the shallow section it studied, down to 5,725 feet below the seafloor. So it weakens the blanket claim of similar pore pressures and geology but doesn't disprove it for the full well.
The agency’s words, the record and the law +Hide the words
The agency says
“Walter has gained pore pressure and geology information in this area and this well will be similar pore pressures and geology to the offset wells.”
Attachment 2-A
Elsewhere in the same document
“Because of this difference in acoustic character, the offset wells are not considered a direct analog to the conditions interpreted at the proposed well location.”
Attachment 3-D
“Historically in this general region, this unit has produced water flow events.”
Attachment 3-D
The law
“ensure the professional integrity, including scientific integrity, of the discussion and analysis in an environmental document; (E) make use of reliable data and resources in carrying out this chapter;” National Environmental Policy Act, 42 U.S.C. 4332(2)(D)-(E) ↗
What the document never analyzes
Not analyzed
Greenhouse gas emissions and climate
The emissions worksheets total diesel engine and well-test flaring pollutants for six years, including up to 1,316.37 tons of nitrogen oxides a year, but they don't list any greenhouse gases.
Searched all 128 pages for ‘greenhouse’, ‘climate’, ‘carbon dioxide’, ‘methane’. None appear.
Not analyzed
Tribal consultation on prehistoric sites
The plan says the block lies inside the prehistoric archaeological high-probability lines and that no agencies or persons were consulted. It never mentions tribes connected to the Louisiana coast its spill trajectories reach.
Searched all 128 pages for ‘tribe’, ‘tribal’, ‘native american’, ‘indigenous’. None appear.
Where its own record backs the agency
EffectsNothing about the project is likely to affect the endangered Rice's whale, because the whale's area is far away and vessels won't pass through it.Why it holds +
The Rice's whale section puts the whale's area over 130.5 miles from the well and says support vessels won't pass through it. That section points readers to the marine mammals section. There, the plan finds the effects of helicopter noise insignificant to Rice's whales and commits vessels to stay 500 meters or more from baleen whales. It also covers moon pool monitoring. Together these support the conclusion. Two loose ends remain. Table 1 marks the Rice's whale as potentially present in the lease area, and the vicinity map gives the distance as about 234 statute miles, not 130.5.
The agency says
“Therefore, there are no IPFs from the proposed operations that are likely to impact the Rice’s whale.”
20.1
Its own record backs it
“There are less than 100 Rice’s whales living in the Gulf of America year-round.”
20.1
EffectsDrilling isn't likely to harm deepwater seafloor communities.Why it holds +
The site-specific hazards letter used 3D seismic and near-seafloor survey data. It found no features that could support high-density seafloor communities within 2,000 feet of the well. The nearest known community site is about 1.5 miles away, in Ewing Bank Block 1010. Walter commits to keeping discharge points 2,000 feet from any such community, and the rig uses no anchors.
The agency says
“Due to the distance from the closest known deepwater benthic community and because physical disturbances to the seafloor will be minimized by the use of a DP semisubmersible, Walter’s proposed operations in Ewing Bank Block 966 are not likely to impact deepwater benthic communities.”
Deepwater Benthic Communities
Its own record backs it
“No areas with the potential for fluid venting and the potential for benthic communities occur at or within 2,000ft radius of the proposed well.”
Attachment 3-D
EffectsAir emissions from the rig and support vessels stay below the federal exemption levels.Why it holds +
The emissions worksheets in Attachment 7-A back this. The highest annual total for any pollutant is 1,316.37 tons of nitrogen oxides, in each year from 2027 through 2030. That's below the lowest allowable figure shown, 2,297.70. Totals for particulates, sulfur oxides and volatile organic compounds are far lower. Helicopter trips, listed only as needed, don't appear in the worksheets.
The agency says
“Plan Emissions for the proposed operations do not exceed the annual exemption levels as set forth by BOEM.”
Air Quality
Read from the agency’s own decision document ↗, all 128 pages. Every quote is checked word for word against it, a claim marked contradicted stands on a quote from the same document, and a second reading argued the agency’s side of every verdict before it was published. The verdicts are our reading; the quotes are the agency’s. A court can set aside agency action it finds “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law” (5 U.S.C. 706(2)(A) ↗), which is why these gaps are worth putting in the record.
What to say
What the public could have raised, from the agency’s own document
- I oppose this action as proposed, and I ask the agency to weigh the specific harms below.
- The environmental impact analysis states the endangered Rice's whale area, home to fewer than 100 individuals, is over 130.5 miles from the well. But the plan's own vicinity map in a separate attachment puts the same distance at roughly 234 statute miles, nearly 100 miles further. A species with a population this small and this vulnerable deserves an accurate, consistent distance calculation, not two conflicting numbers in the same submission. The agency should require the operator to correct and reconcile the Rice's whale distance figures before relying on either one.
- For the worst-case blowout scenario that underpins the entire spill response plan, the operator admits it simply does not have the data to say whether the well could bridge over on its own, a factor that materially affects how long oil would flow and how much would ultimately spill. Rather than commissioning analysis or citing comparable well behavior, the plan just states the question is unanswered and moves on. The agency should require the operator to obtain or cite empirical data on bridge-over likelihood before accepting the 6,226,000-barrel worst-case volume as adequately supported.
- The plan states there are no environmental monitoring systems currently in place or planned for any of the proposed activities, despite operating in water depths where deepwater benthic communities, live bottoms, and multiple endangered species may occur nearby. Without any monitoring commitment, there is no mechanism to detect impacts to water quality, marine life, or seafloor communities as drilling proceeds through 2031. The agency should require baseline and operational environmental monitoring as a condition of approval.
- The operator justifies its spill-response adequacy by noting this well's worst-case discharge, 62,260 barrels, is smaller than the 432,298-barrel worst case in its Regional Oil Spill Response Plan. But it never analyzes that this well's oil is heavier, at 29 degrees API versus 37 degrees API for the regional scenario, and closer to shore, at 69 miles versus 74 miles, both factors that could make response harder even at a lower volume. The agency should require a site-specific adequacy analysis rather than a volume-only comparison to the regional plan.
Show every point from the document
- Say something only you can say. The law requires the agency to consider and respond to substantive comments, and specifics are what make a comment substantive.
In the agency’s own words
Other
On the record for this fight
1 person has filed on this fight through PLAN. The official record is still catching up.
- Emily, California32 seals
Ranked on letters found on the agency’s record, then letters filed. Readers appear as first name and last initial, or as a steward in their state; switch yours off in your record. All boards
Did the agency answer?
4 issues are on this record. The agency has not published its decision document yet, so each one stays pending until the agency answers.
Issues on the record, awaiting the decision
- PendingThe operator justifies its spill-response adequacy by noting this well's worst-case discharge, 62,260 barrels, is smaller than the 432,298-barrel worst case in its Regional Oil Spill Response Plan.
The operator justifies its spill-response adequacy by noting this well's worst-case discharge, 62,260 barrels, is smaller than the 432,298-barrel worst case in its Regional Oil Spill Response Plan. But it never analyzes that this well's oil is heavier, at 29 degrees API versus 37 degrees API for the regional scenario, and closer to shore, at 69 miles versus 74 miles, both factors that could make response harder even at a lower volume. The agency should require a site-specific adequacy analysis rather than a volume-only comparison to the regional plan.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe environmental impact analysis states the endangered Rice's whale area, home to fewer than 100 individuals, is over 130.5 miles from the well.
The environmental impact analysis states the endangered Rice's whale area, home to fewer than 100 individuals, is over 130.5 miles from the well. But the plan's own vicinity map in a separate attachment puts the same distance at roughly 234 statute miles, nearly 100 miles further. A species with a population this small and this vulnerable deserves an accurate, consistent distance calculation, not two conflicting numbers in the same submission. The agency should require the operator to correct and reconcile the Rice's whale distance figures before relying on either one.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingFor the worst-case blowout scenario that underpins the entire spill response plan, the operator admits it simply does not have the data to say whether the well could bridge over on its own, a factor t
For the worst-case blowout scenario that underpins the entire spill response plan, the operator admits it simply does not have the data to say whether the well could bridge over on its own, a factor that materially affects how long oil would flow and how much would ultimately spill. Rather than commissioning analysis or citing comparable well behavior, the plan just states the question is unanswered and moves on. The agency should require the operator to obtain or cite empirical data on bridge-over likelihood before accepting the 6,226,000-barrel worst-case volume as adequately supported.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe plan states there are no environmental monitoring systems currently in place or planned for any of the proposed activities, despite operating in water depths where deepwater benthic communities, l
The plan states there are no environmental monitoring systems currently in place or planned for any of the proposed activities, despite operating in water depths where deepwater benthic communities, live bottoms, and multiple endangered species may occur nearby. Without any monitoring commitment, there is no mechanism to detect impacts to water quality, marine life, or seafloor communities as drilling proceeds through 2031. The agency should require baseline and operational environmental monitoring as a condition of approval.
A hole PLAN found in the agency’s own analysis, quote verified against the document
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