October 6, 2022
Ms. Kelly Hammerle
Chief, National OCS Oil and Gas Leasing Program
U.S. Bureau of Ocean Energy Management
45600 Woodland Road
Sterling, VA 20166
Re: Comments on the 2023-2028 Proposed Outer Continental Shelf Oil and Gas Leasing Program and Draft Programmatic Environmental Impact Statement (Docket ID: BOEM-2022-0031)
Ms. Hammerle:
The Southern Environmental Law Center (“SELC”) submits these comments on behalf of Charleston Waterkeeper, Coalition to Protect America’s National Parks, Conservation Voters of South Carolina, Defenders of Wildlife, Environment Georgia, Friends of the Earth, Lynnhaven River NOW, Mobile Baykeeper, Mobile Environmental Justice Action Coalition, National Parks Conservation Association, N.C. Coastal Federation, N.C. Conservation Network, N.C. Council of Churches, N.C. Interfaith Power and Light, N.C. League of Conservation Voters, NY4WHALES, Ocean Conservation Research, Ogeechee Audubon Society, One Hundred Miles, S.C. Wildlife Federation, S.C. Coastal Conservation League, Sierra Club Alabama Chapter, Stop Offshore Drilling in the Atlantic, Surfrider Foundation Georgia, and Virginia Conservation Network, regarding the Bureau of Ocean Energy Management’s (“BOEM”) 2023- 2028 Proposed Outer Continental Shelf Oil and Gas Leasing Program (“PP”) and Draft Programmatic Environmental Impact Statement (“DPEIS”).1Notice of Availability of the 2023-2028 National Outer Continental Shelf Oil and Gas Leasing Proposed Program and Draft Programmatic Environmental Impact Statement, 87 Fed. Reg. 40,859 (July 8, 2022). These comments will focus on the PP and DPEIS analyses specifically regarding the Atlantic and Gulf of Mexico.
Our organizations have long been opposed to the substantial threat that dirty offshore oil and gas drilling poses to our natural resources, coastal economies, and local communities. We have consistently opposed proposals to open areas in the Atlantic to offshore drilling, and have highlighted the need to transition to a more resilient clean energy economy in the Gulf, most recently in April 15, 2021 comments to President Biden’s review of the offshore oil and gas leasing program.2Letter from SELC et al. to Laura Daniel Davis, Principal Deputy Assistant Sec’y, Land & Minerals Mgmt., U.S. Dep’t of Interior (DOI), Re: Comments on a Request for Input on the Department of Interior’s Review of the Federal Oil and Gas Program (Apr. 15, 2021) [hereinafter “SELC Oil and Gas Review Comments”], provided as Attachment 1. As demonstrated by the Deepwater Horizon disaster in 2010, oil spills cause severe immediate and long-lasting damage to marine and coastal environments. Even in the absence of catastrophic spills, offshore oil and gas development consistently results in smaller, chronic spills that appear to simply be the cost of doing business. In addition, the extraction, production, and consumption of fossil fuels is indisputably the primary contributor to the greenhouse gas accumulation causing climate change.3Gabriel Blanco et al., Drivers, trends, and mitigation, in CLIMATE CHANGE 2014: MITIGATION OF CLIMATE CHANGE, 351-411 (Ottmar Edenhofer et al. eds., 2014), https://www.ipcc.ch/site/assets/uploads/2018/02/ipcc_wg3_ar5_chapter5.pdf. The Southeast coast is already being negatively affected by sea level rise, flooding, and extreme storms, underscoring the need to take immediate action to address climate change and the burning of fossil fuels that drives it.
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