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Comments on Interior’s Offshore Oil and Gas Leasing 2019-2024 Draft Proposed Program

The Department of the Interior’s offshore leasing program must analyze and account for the potential for environmental damage, the potential for the discovery of oil and gas, and the potential for adverse impact on the coastal zone. In addition, offshore oil and gas leases must provide fair market value for private use and development of these publicly-owned oil and gas resources. Our comments to the Interior’s Bureau of Ocean Energy Management (BOEM) explain why its Draft Proposed Program for 2019-2024, which would replace BOEM’s existing Program for 2017-2022, fails to meet its statutory mandates under the Outer Continental Shelf Lands Act (OCSLA).

BOEM must take additional steps to strengthen its analysis in order to meet OCSLA’s requirements, including its duty to balance economic, social, and environmental values in managing the Outer Continental Shelf. For example, BOEM states that it is considering decreasing royalty rates collected for extraction of these public resources; but lowering the royalty rate and continuing to hold uncompetitive lease sales will all but ensure that the public will not receive fair market value. BOEM’s option value analysis is also deficient, which biases it toward including too many areas of the Outer Continental Shelf in the Program.

BOEM also must correct several inaccurate assumptions, errors, and omissions that bias its models and analyses toward leasing and development of the Outer Continental Shelf. These errors include inconsistencies and errors in how it models oil prices, exclusion of many environmental and economic risks in its economic analysis (such as catastrophic oil spills), and lack of transparency.