CRE Establishes a Discussion Forum for Public Comments Submitted to MMS and CEQ on OCS Five Year Plan and Ocean Zoning
In accord with the President’s emphasis on transparency and open government, CRE is posting three influential documents for public review and comment:
(1) NOAA comments to MMS on the Five Year OCS Program, see the NOAA attachment below.
(2) A comment prepared by several dozen environmental organizations on the CEQ Interim Report on Ocean Zoning/Marine Spatial Planning, see Enviro Comments below,
(3) Comments submitted by CRE to CEQ on the Interim Report on Ocean Zoning/Marine Spatial Planning, see CRE CEQ below.
The public is encouraged to comment on each of the above items. CRE has chosen these three articles because in our opinion they define the boundaries of the debate regarding the development of the nation’s energy resources and whether the nation ever has the slightest chance of becoming less dependant upon imported energy, often from threatening regimes.
CRE will review the comments submitted hereto and will give periodic reports to NOAA, CEQ , MMS , other federal agencies and the public. CRE’s previous experience with Interactive Public Dockets (IPD’s) suggests that by establishing a compendium of information, which is updated continuously by the public, it is difficult for federal agencies not to seriously address those issues which have considereable public momentum behind them. To this end, we invite particular attention to CRE’s recommendation #7 on page 10 of its comments (CRE MMS below) in which we recommend that federal agencies announce that they will accept periodic submissions on a continuous basis on the topics addressed herein.
It should be noted that when CRE developed its comments on the OCS Five Year Plan, which are included as an attachment to the CRE’s comments to CEQ on ocean zoning–attached below–CRE provided the public with an opportunity to comment on a draft of the CRE comments; the comments CRE received are available at http://www.thecre.com/zoning-forum/
The public can submit comments on the above documents by:
(1) Posting them on the Discussion Forum at http://www.thecre.com/zoning-forum/
No registration is needed; anonymous comments are accepted. Attachments permitted.
(2) By simply clicking on the term “Comments” in the upper left hand side of this column and typing your message. Again, no registration is needed; anonymous comments are accepted. In this case however, attachments are not accepted.
5 responses to “CRE Establishes a Discussion Forum for Public Comments Submitted to MMS and CEQ on OCS Five Year Plan and Ocean Zoning”
CRE Brazil Recommendations Are Alarming
By Joëlle Hervic
Joëlle Hervic is a litigation attorney, specializing in environmental law. Ms. Hervic’s experience includes Clean Water Act, CERCLA, water law, global climate change, and human rights law. Ms. Hervic’s focus has been on environmental law as an Associate Attorney with an AmLaw 200 law firm, as a consultant with the World Bank and with Waterkeeper Alliance. As Senior Attorney with Waterkeeper Alliance, Ms. Hervic was responsible for addressing deficiencies in the regulation and enforcement of pollution in the Chesapeake Bay from agricultural sources, in particular from Concentrated Animal Feeding Operations.
Comments at http://www.thecre.com/zoning-forum/?p=229
Comments on The Center for Regulatory Effectiveness Conclusions on OCS Leasing and MPAs.
Representing the Alliance of Communities for Sustainable Fisheries (http://www.alliancefisheries.com)
Comments to CRE Comments on Draft Leasing Program
Draft Proposed 5-year Outer Continental Shelf
Oil and Gas Leasing Program for 2010
Comments on the Comments of The Center for Regulatory Effectiveness
By Stephen Wehrly
Mr. Wehrly is an attorney and lobbyist who in 2008 represented an international environmental advocacy organization in Washington, DC, on offshore drilling and related issues, and, for twelve years, an Indian Tribe in Washington state involved in regional environmental and natural resources issues. For 29 years, Mr. Wehrly lobbied legislative and rulemaking venues in Washington, DC, and Washington State on behalf of business, association, and citizen action clients.
Ocean Policy Task Force Public Meeting, 8-21-09 – http://www.northerngaspipelines.com/content/harbour-testimony-ocean-policy-task-force-public-meeting-8-21-09
Testimony: Dave Harbour, Retired Commissioner, Regulatory Commission of Alaska
Madam Chair and members of the Interagency Ocean Policy Task Force:
I am Dave Harbour, a retired Alaska regulatory commissioner. I publish an energy website and serve as a volunteer member of the Consumer Energy Alliance Board of Advisors.
Since you wish to recommend Ocean policy that is based on science and facts I offer you these additional recommendations on ‘process’ as a former Alaskan regulator.
First, On Timing. There are few courts or regulatory bodies that would commit in advance to a full and complete, science-based, factual adjudication of a complex issue within a brief timeframe of six months or three months—especially when multiple parties, as here, should be given ‘due process’. The President has given you one of the most complex challenges in the entire history of natural resources policy making. He has ordered that you produce recommendations for a national ocean policy, a framework for policy coordination of ocean stewardship and an implementation strategy within three months of June 12. He has ordered that you produce a framework for ‘effective’ coastal and marine spatial planning within 6 months of June 12. If quickly transformed into laws and administrative rules, the result could change America and change the world—not just ocean policy–and not necessarily for the better. Deadlines now loom within sight. As good advisors, please ask for more time if, as I suspect, this greatest of all natural resources planning projects cannot, by application of science and facts, be comprehensively and competently organized and completed within the dictated timeframe.
Second, On Comprehensive Policy. A sustainable ocean policy presupposes a comprehensive approach. A little while ago, University of Alaska-Anchorage Chancellor Fran Ulmer spoke of the importance of your producing a ‘comprehensive’ policy. She made reference to the significant body of knowledge available to you through the University of Alaska. To not identify, subsume into your record and analyze such relevant material, along with that produced from other oceanographic, Sea Grant, aquaria, military, maritime and similar public and private sources would be to debase the importance and value of your work. Nor should the body of knowledge you assemble and analyze be restricted to U.S. institutions since the oceans, like knowledge, are not limited by national boundaries.
Third, Other Relevant Ocean Policy Issues. A valid oceans policy must recognize the dangers of creating unintended consequences by fully understanding and evaluating related issues. I would urge the task force to create–as full and equal portions of your recommendations–analyses of the social, economic, cross-polar, cultural, energy and national defense implications of America’s Ocean Policy.
Fourth, Other Alaska and National Concerns.
Money. With Trans Alaska Pipeline throughput dipping by about 6% annually, America’s dependence on foreign sources increases proportionally, just as Alaska’s state government revenue—over 80% dependent on oil—creeps dangerously lower. Alaska’s and America’s most prolific new energy resources will come from the Alaska OCS. To properly survive, Alaska’s government needs the full, undiluted 37.5% of OCS rents, royalties and bonus moneys now accorded some Gulf of Mexico states. The Federal government, seeking to repay the enormous economic stimulus spending could help control inflation and repay debt by sponsoring a strong, Federal OCS program in Alaska and the Lower 48. OCS activity monitored under current laws and regulations will produce hundreds of thousands of jobs for Americans and jump start the economy unlike the way that any artificial stimulus could.
National Security. Yesterday Prime Minister Harper was visiting our neighbors to the East, in the northern territories. It was his 4th Arctic tour. He came with Arctic announcements, including infrastructure to be provided by CanNor, a new, Arctic regional economic development agency. The agency will provide for roads, ports and other infrastructure. He also observed Operation Nanook, the Canadian Forces’ annual sovereignty exercise in the eastern Arctic. And protecting our sovereign Arctic waters—as Mr. Harper is doing—is arguably as important as protecting the natural values. We in this room have heard of the Russian Federation plans for the Arctic. Today our Coast Guard Commandant articulated his three-fold mission in this Task Force effort but none of those missions seemed focused upon establishing, extending and safeguarding the United States’ jurisdiction and sovereignty in the Arctic…when the Canadians and Russians are making sovereignty and jurisdiction a high priority mission.
Yes, Madam Chair, the task force assignment may be well intended. But you can only fulfill your purpose by carefully considering the web of interconnecting environmental, economic, natural resources, cultural, intra-polar, political and military imperatives and realities. To create within a half-year an ocean policy recommendation that treats some Arctic values but not all would be to predetermine winning and losing values before assembling and analyzing a complete and factual record. Your recommendation would be labeled incomplete or incompetent, in spite of dedication or herculean efforts, simply because you were not granted sufficient time to professionally complete the mission. Please tell the President that you need more time to do it properly.
The President’s direction concerning, “National Policy For The Oceans, Our Coasts, and the Great Lakes,” is a concept that must be fully–not partly–investigated to assure the avoidance of very bad, unintended consequences—including those which could unintentionally harm American citizens or the very oceans themselves.
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