We recently submitted comments to BOEM in response to its proposed five-year offshore leasing program for 2017-2022. In its proposed program, BOEM qualitatively considers the option value, or informational value of delaying leasing until more information is available on relevant environmental, social, and technological uncertainties. In addition, BOEM will now consider environmental and social costs in its “hurdle price” analysis that helps determine whether and when to offer areas for lease. Building on this progress, we recommend that BOEM take additional steps to strengthen its analysis in line with best practices and OCSLA’s mandate to balance economic, social, and environmental values. More specifically our comments advocate for the expanded use of option value in agency decisionmaking, as well as the consideration of downstream greenhouse gas emissions in future decisions. In addition, we provide suggestions for improving BOEM’s modeling.
Related Reading
-
Interior’s Authority to Consider Downstream Emissions from Offshore Leasing
Publications / October 6, 2022
-
The Real Costs of Offshore Oil and Gas Leasing: A Review of BOEM’s Economic Analysis for Its Proposed Five-Year Program
Publications / September 30, 2022
-
Comments on FERC’s Office of Public Participation
Project Updates / April 23, 2021
-
Comments to ACUS on Periodic Review of Agency Regulation
Project Updates / April 9, 2021
-
Comments to ACUS on Regulatory Alternatives
Project Updates / April 6, 2021