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Comments on Proposed Offshore Leasing Program for 2017-2022

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.