Dick Wilderman has shared his comments he submitted to BOEM last July in response to their Request for Information. He shares these comments with you and gives permission to include some or all of his comments in your BOEM comments that are due March 6th.
Directions for filing a comment online can be found here:
You can mail in your comments to:
Ms. Kelly Hammerle, National OCS Oil and Gas Leasing Program Manager, BOEM (VAM-LD), 45600 Woodland Road, Sterling, Va., 20166-9216.
In March 2016 the Obama Administration removed the mid- and south Atlantic
areas from the 2017 – 2022 OCS oil and gas leasing program. The Department
of the Interior stated in the proposed program that the Atlantic areas were
removed for the following reasons: strong local opposition, conflicts with other
ocean uses, current market dynamics, consideration of comments from
governors of affected states, the potential for environmental damage, the
(minimal) potential for the discovery of oil and gas, and the potential for adverse
impacts on the coastal zone.
Government scientists and other subject-matter experts in the Department and
other federal agencies conducted the research and analyses that were the basis
for the administration’s decision to remove the Atlantic areas from the 5-year
leasing program. The Trump Administration is reversing that decision. Has
anything changed since last year that would justify this reversal? Except for
obvious political differences, the substantive issues used to decide which areas
to exclude from offshore oil drilling are still valid. With that in mind, let’s look at
the seven reasons the Atlantic was removed last year and see if anything has
Strong local opposition: Local opposition on the East Coast to offshore drilling
has become even stronger and more vocal since President Trump came out in
favor of more offshore drilling during his campaign for president. There is every
indication that local, region, and state opposition will continue to grow.
Conflicts with other ocean uses: The military activities that DOD commonly
seeks to protect from interference include military munitions practice using
offshore areas; the spatial use of water and airspace for port access and offshore
ship and plane maneuvers; and potential launch-abort areas for missile launches
from military bases and secure military communications. These activities are
critical to military readiness and national security. Increased military spending
proposed by President Trump is likely to increase conflicts with military activities
in the Atlantic. Conflicts with other ocean uses — including fishing, commercial
vessel traffic, ocean-dependent tourism, and renewable energy projects — also
will increase, not decrease, in the years ahead.
Current market dynamics: The Department stated in the 2017 – 2022 offshore
program decision document that, “In the absence of a new OCS program,
energy markets would adjust and substitute energy sources would be
necessary.” That is still the case. In an interview in 2000, the Saudi Arabian oil
minister said, “the oil age will end long before the world runs out of oil.” But the
oil industry desperately fights to slow its inevitable demise by trying to sustain our
reliance on fossil fuels at a time when energy markets are moving to more
efficient, reliable, environmentally sustainable, and economically stable sources.
There have been no changes in the energy markets since last year to justify
including the Atlantic in a new leasing program.
Consideration of comments from governors of affected states: Historically, and in
accordance with the OCS Lands Act, the opinions of governors of coastal states
are an important consideration in deciding which areas to exclude from the 5-
year program. Last year the federal government removed the Atlantic areas at a
time when the Governor of South Carolina, Nikki Haley, supported offshore oil
and gas development. We now have a governor, Henry McMaster, who is
opposed to offshore drilling. Opposition from governors of affected states is
stronger now than last year.
The potential for environmental damage: The marine environment is no less at
risk from offshore drilling now than it was a year ago. It is worth noting that a
2016 U.S. Government Accountability Office report concluded that the Bureau of
Safety and Environmental Enforcement failed to adequately meet its safety and
environmental compliance regulatory responsibilities as mandated after the 2010
Deepwater Horizon catastrophe in the Gulf of Mexico. The truth is the
environment will be even more at risk in the months and years ahead as the
administration eliminates or weakens safety and environmental regulations for
offshore oil and gas activities as it clearly set out to do in the April 28, 2017,
executive order implementing the America-First Offshore Energy Strategy.
The potential for the discovery of oil and gas: The south Atlantic has some of the
lowest resource potential of all offshore areas. Two exploratory wells were drilled
in the south Atlantic in the 1980s, and no commercial oil or gas was discovered.
The U.S. currently exports about a million barrels of oil a day. If we needed more
oil to be “energy dominant”, we could just keep that oil here. The potential for the
discovery of oil or gas in the Atlantic is no greater this year than last.
The potential for adverse impacts on the coastal zone: As is the case with the
entire marine environment, the coastal zone is still as much at risk, or more so,
from offshore drilling impacts as it was last year. The same environmental laws
and regulations apply, yet the Trump administration has taken steps to weaken
them in order to, as they say, eliminate over-regulation.
Obviously the non-political reasons the Atlantic was excluded from the offshore
drilling program last year still apply, and in some cases are even stronger. As
everyone knows, re-introducing Atlantic areas into the leasing program would be
a purely political decision. Don’t do it.