Lapis Energy Lake Salvador Carbon Sequestration Project

Submit comments to the Office of Coastal Management regarding Coastal Use Permit P20240989

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Deadline: April 23, 2025

Project Summary for OCM Consideration

Critical Coastal Concerns

The Lapis Energy Lake Salvador Carbon Sequestration Project proposes CO₂ injection wells, access roads, and related infrastructure in Louisiana wetlands. The project would significantly impact coastal resources under OCM's jurisdiction and conflicts with existing coastal restoration efforts.

  1. Direct conflicts with Louisiana's existing coastal restoration initiatives in the Lake Salvador area
  2. Significant wetland impacts with inadequate mitigation planning
  3. Hydrological alteration from infrastructure impeding natural water flow in coastal wetlands
  4. Impacts on protected species including the Alligator Snapping Turtle and Pallid Sturgeon
  5. Interference with traditional coastal uses including fishing, hunting, and ecotourism
  6. Inadequate Hydrologic Modification Impact Analysis (HMIA) that fails to address groundwater impacts
  7. Insufficient alternatives analysis to demonstrate avoidance of wetland impacts
Project Details Relevant to OCM
OCM Permit: P20240989
Location: Lake Salvador, LA
Comment Deadline: April 23, 2025
Project Infrastructure in Coastal Zone:
  • 24' x 33,980' access road across wetlands (approximately 6.4 miles)
  • 400' x 400' injection well pad
  • Pipeline trenching
  • Total wetland impact: 10.69 acres of freshwater emergent wetland (classified as PEM1F)
  • Permanent wetland impact: 6.46 acres
Corporate Background

Key ownership information:

  • Lapis Energy is a Denbury company
  • Denbury was acquired by ExxonMobil in November 2023 for $4.9 billion
  • This project is part of a larger corporate strategy for CO₂ transport and storage
Corporate Compliance Concerns:

ExxonMobil has hundreds of existing compliance issues in Louisiana, including unfulfilled coastal restoration obligations in the Barataria Basin that should be addressed before new permits are issued.

Submit Comments to OCM by April 23, 2025

The Louisiana Department of Natural Resources, Office of Coastal Management is accepting public comments on Coastal Use Permit (CUP) P20240989.

Submit Comment on OCM Site

Or email Emily Eley and mention the permit number (P20240989).

OCM's Role:

The Office of Coastal Management is responsible for implementing the Louisiana Coastal Resources Program and balancing conservation and restoration with coastal economic development.

OCM's Jurisdiction

The Office of Coastal Management specifically reviews:

  • Impacts on coastal wetlands and water quality
  • Alterations to natural drainage patterns
  • Compatibility with Louisiana's Coastal Master Plan
  • Effects on traditional coastal uses (fishing, recreation)
  • Impacts on coastal wildlife and habitats
  • Hydrological modifications in the coastal zone

Your comments should focus on these areas of OCM responsibility.

Aerial view of Lake Salvador wetlands

Location of proposed main well pad in the middle of wetlands.

Impacts on Coastal Resources

Wetland Impacts and Mitigation Deficiencies

The application acknowledges the dominant vegetation is:

  • Maiden cane (Panicum hemitomon) - 80% composition, Obligate Wetland species
  • Southern Bayberry/Wax Myrtle (Morella cerifera) - 10% composition, Facultative species
  • Cattail (Typha sp.) - 5% composition, Obligate Wetland species
  • Roseau cane/common reed (Phragmites australis) - 5% composition, Facultative Wetland species

However, the application is still deficient in several critical areas:

  • No formal wetland type classification (emergent, forested, scrub-shrub)
  • Missing detailed functional assessments of impacted wetlands
  • No explanation of ecological significance of the 10.79 acres to be affected
  • Vague mitigation statement about "utilizing a Corps approved mitigation bank within the watershed" without specific details
  • No specified mitigation ratios or consideration of temporal losses between impact and mitigation
  • No plan for beneficial use of excavated materials, unlike other projects that specify "spoil material will be beneficially placed to support marsh creation"
  • Incomplete restoration planning with no performance standards, monitoring protocols, or contingency planning
Inadequate Hydrologic Modification Impact Analysis

The submitted HMIA contains several unsupported claims:

  • Claims that placing 1-foot of rock will create only a "semi-permeable surface" with infiltration being "only slightly altered" - a claim that contradicts established hydrological principles
  • Asserts "the proposed project will not produce runoff nor impact any existing waterways or drainage networks" - an impossible claim for a 33,980' access road and 400' x 400' well pad
  • Completely fails to address groundwater impacts, focusing only on surface water
  • Claims "any influence the project may have upon the marsh surface hydrology is restricted to immediate surroundings" without any supporting data or analysis
  • Does not address how infrastructure will affect southerly flow toward Bayou Des Allemands and Lake Salvador

Direct Conflicts with Louisiana's Coastal Restoration Initiatives

Lake Salvador shoreline protection projects
Louisiana's Coastal Master Plan Projects
Lake Salvador Shoreline Protection Demonstration Project (BA-15)
  • Targets shoreline erosion along Lake Salvador's northern and southwestern shores
  • Phase I tested various shoreline protection structures along 5,900 feet of the northern shoreline
  • Has demonstrated shoreline gain of 1.8 feet per year in protected areas
Des Allemands Swamp Restoration:
  • Hydrologic restoration to alleviate impoundment conditions
  • Vegetative planting including cypress and tupelo saplings
More Lake Salvador Shoreline Protection Details:
  • Phase II features a 9,000-foot rock shoreline stabilization structure along the southwestern shore, near Bayou Des Allemands
  • The proposed project would undermine these efforts through altered hydrology and wetland destruction
More Des Allemands Swamp Restoration Details:
  • Aims to enhance 2,395 acres of swamp habitat
  • Located west of Lac des Allemands in St. James Parish
  • The proposed project could interfere with restored hydrology
Critical Habitats and Protected Species
Salvador Wildlife Management Area Features
  • Freshwater and Intermediate Marsh Systems: Provide essential habitat for waterfowl, furbearers, and alligators
  • Cypress-Tupelo Swamps: Large stands in the northern portions of Salvador WMA
  • Old Natural Stream Levees: Support cypress stands that were once distributary channels of the Mississippi River
Protected Species in the Coastal Zone

The coastal zone likely provides habitat for several protected species that could be impacted:

  • Alligator Snapping Turtle (proposed threatened): Permanent loss of habitat for feeding and nesting
  • Pallid Sturgeon (endangered): Potential impacts from sedimentation and water quality changes
  • Eastern Pygmy Blue butterfly (imperiled): Habitat fragmentation affecting this sensitive species
  • Imperiled plant species: Dwarf Bulrush, Floating Antler Fern, Square-stem Monkeyflower, and Swamp Milkweed could be directly eliminated by clearing activities
  • Bald Eagle: Previously endangered, now delisted but still protected - nesting documented in coastal Louisiana
Impacts on Traditional Coastal Uses
Fishing
  • LDWF describes "excellent" freshwater fishing for bass, bream, crappie, catfish, drum, and garfish
  • Area supports recreational fishing for redfish, speckled trout, and other species
Hunting
  • Waterfowl: 380 ducks harvested in a single opening day
  • Deer: Notable achievements include Matt Caire's eight-point swamp buck
  • Also supports hunting for rabbit, squirrel, rails, gallinules, and snipe
Wildlife Viewing
  • Bird watching in freshwater marsh with scattered ponds
  • Salvador WMA provides exceptional habitat for waterfowl, furbearers, and alligators
  • Access via Bayou Segnette from Westwego, Sellers Canal to Bayou Verrett, or Bayou Des Allemands
Tourism
  • 2 Da Swamp Cajun Tours operates from Des Allemands
  • Airboat operators provide wildlife tours
  • Guides share the region's Cajun heritage and history

Environmental Research Supporting Concerns

Scientific Evidence of Environmental Impacts
Research Documenting Infrastructure Impacts in Wetlands
Hydrological Disruption
  • Flook et al. (2020): CO₂ wells and infrastructure alter groundwater systems through changed pressure and flow patterns in spring wetlands
  • Plach et al. (2017): Road construction specifically impedes groundwater movement across wetlands, creating hydrological barriers
  • Lemmer et al. (2020): Documented "an average rise in water table level of 10.4 cm in restored sectors compared to 5.6 cm in reference sectors"
Infrastructure Effects
  • Plach et al. (2017): "Semi-permanent road placement is linked to significantly reduced net CO₂ sequestration on the downflow side"
  • Research shows roads create measurable differences in vegetation composition and CO₂ exchange rates on either side
  • Saraswati et al. (2023): "Access roads are linked to reduced growing season carbon uptake in adjacent peatlands"
  • Research specifically recommends "aligning roads parallel to local water flow and equipping them with culverts that enhance hydrological connectivity" - approaches not adequately implemented in this project
Biodiversity Impacts
  • Brittingham et al. (2014): Identified risks to wildlife and aquatic resources, particularly for species with limited range, small population size, specialized habitat requirements, and high sensitivity to disturbance
  • Plach et al. (2017): Documented long-term impacts of infrastructure on plant communities with observable differences in vegetation composition near infrastructure
  • Edge effects and habitat fragmentation extend well beyond the direct footprint of infrastructure
Cumulative Regional Impacts
Part of a Larger Network of CO₂ Projects

This project is one of numerous interconnected CO₂ injection and pipeline proposals in the Barataria watershed by the same corporate entities, including:

  • Denbury Pegasus, Aries, and Gemini projects
  • Exxon Low Carbon initiatives
  • Modifications to existing pipeline systems in the area
Safety Concerns Based on Existing Infrastructure
  • The existing CO₂ pipeline in Louisiana has experienced major accidents approximately every two years
  • A recent CO₂ pipeline incident in Yazoo County, Mississippi resulted in 50 people being hospitalized
Cumulative Impact:

There are over 40 similar injection sites proposed within the New Orleans and Vicksburg Districts, with potential CO₂ pipelines extending over 800 miles and impacting an estimated 3,000-4,000 acres of wetlands directly.

Evidence-Based Minimization Strategies Missing from Application
Research-Supported Approaches to Reduce Wetland Impacts
Infrastructure Design and Placement
  • Match Natural Elevations: Lemmer et al.'s research shows adjusting surface elevations of well pads to match surrounding wetlands improves hydrological function
  • Align with Water Flow: The application shows no consideration for aligning access roads parallel to local water flow patterns
  • Use Permeable Surfaces: No consideration for permeable pavements that allow water flow through road surfaces
Hydrological Management
  • Groundwater Preservation: No measures to address impeded groundwater flow that research shows affects vegetation and carbon sequestration
  • Consider Wildlife Movement: No animal crossing structures (tunnels or overpasses) designed to maintain wildlife connectivity
Beneficial Use Opportunities
  • Spoil Material for Marsh Creation: Unlike other carbon sequestration projects, no plans to use excavated material beneficially for coastal restoration
  • Integration with Restoration Goals: No coordination with existing coastal restoration initiatives to enhance rather than hinder those efforts
  • Comprehensive Monitoring Program: No monitoring for water table levels, carbon flux, vegetation changes, and wildlife impacts
  • Success Criteria: No defined metrics for evaluating restoration success and triggering remedial actions if needed

Permit Application Deficiencies Relevant to OCM

Insufficient Avoidance & Minimization
  • No evidence of infrastructure design optimization to reduce wetland impacts
  • No consideration for aligning access roads with natural water flow patterns
  • No justification for the dimensions of the 33,980' access road and 400' x 400' injection well pad
  • No consideration of elevated roads or bridges to maintain surface and subsurface water flow
  • No monitoring program for water table levels, vegetation changes, or wildlife impacts
  • No plans for beneficial use of excavated materials for coastal restoration
Inadequate Coastal Impact Analysis
  • No assessment of compatibility with Louisiana's Coastal Master Plan
  • No evaluation of impacts on existing restoration projects like the Lake Salvador Shoreline Protection Demonstration Project
  • No assessment of impacts on traditional coastal uses such as fishing, hunting, and ecotourism
  • No analysis of effects on protected species in the coastal zone
  • No consideration of how the project would affect boat-only access to Salvador WMA
  • No evaluation of the project's impact on natural drainage patterns and coastal hydrology
  • No assessment of how the project might limit future coastal restoration opportunities
  • Incomplete project scope: The application fails to disclose Denbury's announced plans for a 45-mile pipeline connecting the site to their existing CO₂ network in Donaldsonville, which could impact hundreds of additional wetland acres
  • Missing safety analysis: The application does not address potential risks from the shallow injection depth (7,000-11,000 feet) where existing well boreholes may compromise the confinement layer

Conclusion and Recommendations for OCM

Key Findings Relevant to OCM
  • The project directly conflicts with existing coastal restoration initiatives in the Lake Salvador area
  • The Hydrologic Modification Impact Analysis contains unsupported claims that defy basic scientific principles
  • The project would significantly alter wetland hydrology with minimal mitigation
  • The application fails to address impacts on protected species and critical coastal habitats
  • The project would negatively affect traditional coastal uses like fishing, hunting, and ecotourism
  • The application lacks evidence-based modifications that would minimize environmental impacts
  • The project fails to consider how infrastructure design affects wetland function and coastal resources
Recommendations for OCM

The Office of Coastal Management should:

  1. Deny the Coastal Use Permit P20240989 in its current form due to insufficient information and unsupported claims in the HMIA
  2. Require a scientifically rigorous hydrological analysis that addresses both surface and groundwater impacts
  3. Demand specific details on culvert design and placement with supporting calculations demonstrating effectiveness
  4. Require a comprehensive analysis of how the project would impact existing coastal restoration projects
  1. Mandate a detailed assessment of impacts on threatened and endangered species in the coastal zone
  2. Insist on specific mitigation measures based on scientific research, including alignment of access roads parallel to water flow and beneficial use of excavated material
  3. Request a public hearing to allow coastal stakeholders to provide their knowledge and concerns
  4. Require a Programmatic Environmental Impact Statement (PEIS) to evaluate the cumulative impacts of all related CO₂ projects in the region rather than reviewing this project in isolation

Submit OCM Comments Before April 23, 2025

Your voice matters! Submit your comments on the Lapis Energy Lake Salvador Carbon Sequestration Project to the Office of Coastal Management.

Submit Comment to OCM Email Emily Eley

When submitting, be sure to reference Coastal Use Permit P20240989
Focus your comments on coastal impacts within OCM's jurisdiction