In November, the Bureau of Ocean Energy Management proposed to amend the nation’s five-year offshore leasing program to substantially expand oil and gas leasing. While proposing this significant shift in federal policy, BOEM offered relatively sparse analysis of the impacts on climate change and other environmental externalities that increased offshore leasing would cause. Our comments urged that it conduct the following analysis:
- BOEM should quantify and monetize all greenhouse gas emissions resulting from the program—downstream, upstream, and midstream. Those impacts are within BOEM’s authority to consider, and failing to assess them would be inconsistent with the agency’s focus on the downstream economic benefits from increased offshore production.
- BOEM should update its analysis of production substitutes to account for recent evidence and long-term shifts in the global energy market. BOEM uses its Market Simulation Model even though it has previously recognized the limitations in this model and provided additional analysis using alternative inputs.
- BOEM should more robustly analyze the impacts of accidental oil spills, including quantifying the risks and costs of oil spills of all sizes and accounting for the heightened damages of oil spills arising from new leasing regions.
In short, our comments argued that BOEM does not provide the analysis necessary to support a substantial leasing increase.