CRE Comments on Enviro Comments on BOEM’s Draft 2017-2022 Plan EIS

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,, 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.

These vituperative and often personal attacks stem from the Enviro’s misguided belief that anything ‘promoting the continuation of fossil fuel-based economy is unconscionable beyond the magnitude of being psychopathic.’

The Enviro’s belief that fossil fuel production and use should be banned is irrelevant to BOEM’s job and authority under the OCS. Part of that job and authority is leasing for offshore oil and gas exploration and production.

After many years of leasing, and after much study, there is no evidence of harm from oil and gas seismic under long-standing regulation by BOEM and by other federal agencies. BOEM’s Chief Environmental Officer William Y. Brown recently explained that

‘To date, there has been no documented scientific evidence of noise from air gun geological and geophysical (G&G) seismic activities adversely affecting animal populations.’

Dr. Brown also notes that

‘because of its abundance, the bottlenose dolphin heads the class in number of potential exposures to air gun sound levels with potential effects on behavior. Yet Federal stock assessments for the dolphin do not identify air gun seismic surveys as adversely impacting stock sustainability in the Gulf of Mexico, where air gun surveys are routine.’

Regulation of seismic is both widespread and effective. The Enviro Comments don’t withstand close scrutiny.

We have sent our comments to Oceana Conservation Research (“Enviro”) and to other commenters on the PEIS and on BOEM’s DPP. We will post any response we receive from them on the CRE websites: Regulation: Seismic Exploration, or on Discussion Forum for Marine Sound.”

Click here to read CRE’s entire comments.

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