Business Alliance For Protecting The Atlantic Coast
Ideas for Comments to BOEM
February 7, 2018 - By: - In: BAPAC Blog - Tags: , - Comments Off on Ideas for Comments to BOEM

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.

Richard Wildermann