CRE Comments on BOEM ICR

CRE recently filed comments on the Bureau of Ocean Energy Management’s Information Collection Request for BOEM’s offshore oil and gas permitting program. CRE’s comments disagreed with BOEM’s response to CRE’s comments on this ICR, which affects BOEM’s permitting process for offshore oil and gas seismic. CRE’s previous comments had requested that BOEM withdraw its petition to the National Marine Fisheries Service for a regulation under the Marine Mammal Protection Act governing the taking of marine mammals in the Gulf of Mexico. BOEM’s response stated, “This comment is outside the scope of this information collection renewal.” CRE’s latest comments pointed out that CRE’s request for withdrawal is within the scope of this ICR because (citations omitted):

“The information collections covered by this ICR demonstrate the wealth of data that BOEM has collected on oil and gas seismic for decades. CRE has repeatedly pointed out to BOEM and the National Marine Fisheries Service (“NMFS”) that these data have supported long-standing regulations that have adequately protected the environment for decades.2 BOEM’s request to NMFS for Marine Mammal Protection Act Take rules for the Gulf of Mexico (“GOM”) can only result in unnecessary regulation and information collections which are duplicative of this ICR and which do not minimize the burden on the responding public. This violates the goals of the PRA, which include: “Minimize the burden on the public when collecting and …Ensure that an Information Collection does not duplicate already existing information, or duplicate effort….” GOM Take rules are inconsistent with the PRA’s goals and intent.“

Click here to read CRE’s entire comments.




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