The Center for Regulatory effectiveness filed comments on the U.S. Bureau of Ocean Energy Management’s Notice of Intent to perform an Environmental Impact Statement for BOEM’s Proposed 2019 Beaufort Sea Oil and Gas Lease Sale.
CRE’s comments (footnotes omitted) include the following Executive Summary:
“BOEM seeks comments on the scoping of an EIS that ‘will focus on the potential effects of leasing, exploration, development, and production of oil and natural gas in the’ Beaufort Sea Program Area.1
CRE’s comments focus on oil and gas exploration in the Beaufort: e.g., seismic airguns. BOEM’s EIS website states that the purpose of soliciting public comment on EIS scoping ‘is to identify relevant issues, alternatives, mitigation measures, and analytical tools so that they can be incorporated into the EIS.’
CRE’s comments address these BOEM concerns by asking BOEM
- to defend its policies and regulation against politically motivated and unsupported attacks by environmental NGOs;
- to state that the Beaufort EIS will comply with the Department of Interior’s (“DOI”) Scientific Integrity Policy;
- to identify what Information Quality Act (“IQA “) Guidelines apply to BOEM, and to state that the Beaufort EIS will comply with them;
- to not overestimate the number of exposures and takes predicted to result from exploration based on assumed adverse effects that have never been observed to occur, and which are based on unvalidated and inaccurate modeling;
- to use Line Transect to estimate exposures and takes until and unless models are accurate and properly validated; and
- to emphasize that no one has to use NOAA/NMFS’s Technical Guidance for Assessing the Effects of Anthropogenic Sound on Marine Mammal Hearing (“Acoustic Guidance”).
Click here to read CRE’s entire comments.