CRE Comments on BOEM’s 2017–2022 Outer Continental Shelf Oil and Gas Leasing Program

On July 29, 2014, the Center for Regulatory Effectiveness filed comments on the U.S. Bureau of Ocean Energy Management’s Request for Information and Comments on the Preparation of the 2017–2022 Outer Continental Shelf Oil and Gas LeasingProgram.  CRE’s comments include the following executive summary:

“BOEM and NMFS will conduct environmental reviews of the OCS Program. A recent court opinion and numerous agency studies correctly conclude that oil and gas seismic is safe under current regulation.

Marine mammal populations are increasing. BOEM and NMFS should consider these increasing marine mammal populations in making their Take determinations. Seismic under current regulation will always have a negligible impact on marine mammals. Behavioral responses to seismic (or lack thereof) should be factors in making seismic “small numbers” determinations. Negligible impact should be a factor in determining whether there is a Take at all.

BOEM and NMFS should allow and respond to public comment on how to make the ESA consultation and Marine Mammal Protection Act (“MMPA”) authorization processes more efficient. This public comment should focus on marine mammal effects, or lack thereof.

NMFS’ Biological Opinions and other environmental assessment documents include certifications and documentation of compliance with the Data Quality Act . BOEM should do the same for its OCS Program environmental review documents, and for all its other environmental review documents.”

Click here to read CRE’s comments.



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