On March 29, 2015, the Center for Regulatory Effectiveness filed Comments on the Bureau of Ocean Energy Management’s Notice of Intent to Prepare a Programmatic Environmental Impact Statement for the Outer Continental Shelf 2017-2022 Proposed Oil and Gas Leasing Program, www.regulations.gov, Docket ID: BOEM-2014-0085.
The Executive Summary for CRE’s comments (footnotes omitted) reads as follows:
“I. Executive Summary
CRE’s comments respond to comments filed in this Docket by Ocean Conservation Research (‘Enviro Comments). These comments are typical of environmental groups’ attacks on BOEM’s OCS management, although more strident than most. In particular, the Enviro Comments make incorrect statements about the effects of oil and gas seismic on aquatic life, and irrationally attack BOEM’s regulation of those effects.