2019–2024 

NATIONAL OUTER CONTINENTAL SHELF 

OIL AND GAS LEASING 

DRAFT PROPOSED PROGRAM 

JANUARY 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Front cover photo credits: 

Seabirds 

Miner, Mike. Sandwich Terns looking for a place to rest at the Breton National Wildlife Refuge on Breton Island, Louisiana. 

June 2, 2007. Available online at https://www.flickr.com/photos/boemgov/29796795985/. Accessed July 5, 2017. 

Whale bones 

BOEM file photo. A whale bone arch in Barrow, Alaska. January 1, 1998. Available online at https://www.flickr.com/ 

photos/boemgov/12003471214/. Accessed July 5, 2017. 

Anemone 

Sinclair, James. Close up of the fire coral (Milepora alaicornis) in the East Flower Garden Bank. June 9, 2006. Available 

online at https://www.flickr.com/photos/boemgov/12002579596/. Accessed July 5, 2017. 

Lighthouse 

Photo courtesy John Caplis, Bureau of Safety and Environmental Enforcement (BSEE). 

Flowers 

Photo courtesy of John Caplis, BSEE 

Oil platform 

BOEM file photo. Jack Up Sun. January 7, 2014. Available online at https://www.flickr.com/photos/boemgov/12001369273/. 

Accessed July 5, 2017. 

Right whale 

Nagelkrik. NARW April 14. April 14, 2017. National Marine Fisheries Service permit number 19674. Reprinted with 

permission from the New England Aquarium. 

Fish 

Boland, Greg S. Platform Legs often double as Artificial Reefs Drawing Numerous Fish. June 1, 2003. Available online at 

https://www.flickr.com/photos/boemgov/12003914203/. Accessed July 5, 2017. 

Sea turtles 

Purchased from Adobe Stock. Available online at https://stock.adobe.com/stock-photo/baby-green-turtles/45595203. Licensed 

June 29, 2017. 

Sea lion 

Sanders, Greg. Untitled. No date. Available online at https://www.flickr.com/photos/boemgov/16103362797/. Accessed 

July 5, 2017. 

Horse 

BOEM file photo. Horse at sunrise over Assateague Island. No date. Available online at https://www.flickr.com/ 

photos/boemgov/27103896663/in/album-72157669850182145/. Accessed July 5, 2017. 
 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Table of Contents 

List of Tables ..............................................................................................................................................v 

List of Figures.............................................................................................................................................vi 

Abbreviations and Acronyms ...................................................................................................................ix 

Overview ............................................................................................................................................xii 

Part I: Draft Proposal on the Size, Timing, and Location of OCS Lease Sales.........................1 

2019–2024 National OCS Oil and Gas Leasing Draft Proposal on the Size, Timing, 

and Location of Sales..........................................................................................................1 

Proposal Framework .................................................................................................................................1 

National OCS Program Decision Process.................................................................................................3 

Secretarial Consideration of the Eight OCS Lands Act Section 18(a)(2) Factors ....................................4 

Geographical, Geological, and Ecological Characteristics ...................................................................................4 

Regional and National Energy Markets................................................................................................................4 

Other Uses of the OCS..........................................................................................................................................5 

Industry Interest....................................................................................................................................................5 

Laws, Goals, and Policies of Affected States .......................................................................................................6 

Environmental Sensitivity and Marine Productivity.............................................................................................6 

Environmental and Predictive Information...........................................................................................................6 

Fair Market Value .....................................................................................................................................6 

2019–2024 Draft Proposed Program Lease Sale Schedule.......................................................................7 

Options to be Analyzed in the Proposed Program .................................................................................10 

Alaska Region Program Options ........................................................................................................................10 

Pacific Region Program Options ........................................................................................................................10 

Gulf of Mexico Region Program Options...........................................................................................................10 

Atlantic Region Program Options.......................................................................................................................11 

Part II: Regulatory Framework...................................................................................................1-1 

Chapter 1 OCS Oil and Gas Leasing Program Development Process..........................................1-2 

1.1 Introduction ...............................................................................................................................1-2 

1.2 National Energy Needs..............................................................................................................1-5 

1.2.1 Contribution of Oil and Natural Gas to the U.S. Economy.................................................................. 1-6 

1.2.1.1 Consumption of Energy Sources................................................................................................. 1-6 

1.2.1.2 Balance of Payments and Trade.................................................................................................. 1-7 

1.2.1.3 Energy Security........................................................................................................................... 1-7 

1.2.1.4 Technology ................................................................................................................................. 1-9 

1.2.1.5 Employment and Public Revenues.............................................................................................. 1-9 

1.3 Program Development Process................................................................................................1-10 

1.3.1 Request for Information and Comments ............................................................................................ 1-11 

1.3.2 Draft Proposed Program and Notice of Intent to Prepare a Programmatic Environmental Impact 

Statement............................................................................................................................................ 1-13 

1.3.3 Proposed Program and Draft Programmatic EIS................................................................................ 1-13 

1.3.4 Proposed Final Program and Final Programmatic EIS....................................................................... 1-14 

1.3.5 Program Approval and Record of Decision ....................................................................................... 1-14 

1.4 Lease Sale Process...................................................................................................................1-14 

1.5 Exploration and Development Process....................................................................................1-16 

Chapter 2 Section 18 Factors for Consideration and Balancing ...................................................2-1 

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2.1 BOEM’s Approach to Analyzing Planning Areas.....................................................................2-1 

2.2 Section 18(a): Factors for Determining Size, Timing, and Location of Leasing......................2-2 

2.3 Section 18(a)(3): Balancing the Potential for Environmental Damage, Discovery of Oil and 

Gas, and Adverse Impact on the Coastal Zone.......................................................................2-4 

2.4 Section 18(a)(4): Assurance of Fair Market Value...................................................................2-5 

2.5 Section 18(a): Energy Needs ....................................................................................................2-5 

2.6 Section 18(a)(1): Economic, Social, and Environmental Values .............................................2-5 

2.6.1 Economic Value ................................................................................................................................... 2-6 

2.6.2 Social Value ......................................................................................................................................... 2-6 

2.6.3 Environmental Value ........................................................................................................................... 2-7 

2.7 Judicial Guidance ......................................................................................................................2-7 

Chapter 3 Outreach and Coordination............................................................................................3-1 

3.1 Request for Information and Comments....................................................................................3-1 

3.2 Public Meetings for the National OCS Program and Programmatic EIS ..................................3-2 

Chapter 4 Background, Leasing History, and Status of OCS Planning Areas............................4-1 

4.1 Background................................................................................................................................4-1 

4.1.1 Alaska Region Planning Areas............................................................................................................. 4-3 

4.1.2 Beaufort Sea......................................................................................................................................... 4-3 

4.1.3 Chukchi Sea ......................................................................................................................................... 4-4 

4.1.4 Hope Basin........................................................................................................................................... 4-4 

4.1.5 Norton Basin ........................................................................................................................................ 4-4 

4.1.6 Navarin Basin....................................................................................................................................... 4-5 

4.1.7 St. George Basin................................................................................................................................... 4-5 

4.1.8 North Aleutian Basin............................................................................................................................ 4-5 

4.1.9 Cook Inlet............................................................................................................................................. 4-5 

4.1.10 Gulf of Alaska ...................................................................................................................................... 4-6 

4.1.11 Alaska Planning Areas with No Lease Sales........................................................................................ 4-6 

4.2 Pacific Region Planning Areas ..................................................................................................4-6 

4.2.1 Washington/Oregon ............................................................................................................................. 4-6 

4.2.2 Northern California .............................................................................................................................. 4-7 

4.2.3 Central California................................................................................................................................. 4-7 

4.2.4 Southern California .............................................................................................................................. 4-7 

4.3 Gulf of Mexico Region Planning Areas ....................................................................................4-7 

4.3.1 Western Gulf of Mexico....................................................................................................................... 4-8 

4.3.2 Central Gulf of Mexico ........................................................................................................................ 4-8 

4.3.3 Eastern Gulf of Mexico........................................................................................................................ 4-8 

4.4 Atlantic Region Planning Areas ................................................................................................4-9 

4.4.1 North Atlantic ...................................................................................................................................... 4-9 

4.4.2 Mid-Atlantic......................................................................................................................................... 4-9 

4.4.3 South Atlantic .................................................................................................................................... 4-10 

4.4.4 Straits of Florida................................................................................................................................. 4-10 

Part III: Analysis and Results......................................................................................................4-11 

Chapter 5 Valuation of Planning Areas...........................................................................................5-1 

5.1 Estimating Hydrocarbon Resources ..........................................................................................5-1 

5.2 Introduction to Hydrocarbon Resources on the OCS ................................................................5-1 

5.2.1 Resource Commodities Assessed......................................................................................................... 5-2 

5.2.2 Sources of Data and Information.......................................................................................................... 5-6 

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5.2.3 Geophysical Data Collection (Seismic Surveys).................................................................................. 5-6 

5.2.4 Uncertainty in Resource Assessment ................................................................................................... 5-6 

5.2.5 Resource Assessment Methodology and Output.................................................................................. 5-8 

5.2.6 Unleased Undiscovered Economically Recoverable Resources......................................................... 5-10 

5.2.7 Exploration and Development Scenarios ........................................................................................... 5-14 

5.3 Net Social Value......................................................................................................................5-16 

5.3.1 Net Economic Value Calculation....................................................................................................... 5-17 

5.3.2 Environmental and Social Costs Calculation ..................................................................................... 5-19 

5.3.3 Net Social Value Calculation ............................................................................................................. 5-22 

5.3.1 Results and Conclusion ...................................................................................................................... 5-24 

Chapter 6 Planning Area Location Considerations........................................................................6-1 

6.1 National Energy Markets...........................................................................................................6-1 

6.1.1 Recent Developments in Oil Markets .................................................................................................. 6-1 

6.1.2 Relevant Developments in Domestic Petroleum Markets.................................................................... 6-2 

6.1.3 Relevant Developments in Domestic Natural Gas Markets ................................................................. 6-3 

6.1.4 Oil and Natural Gas Consumption and Production Estimates.............................................................. 6-4 

6.1.5 Future Unpredictability and Possible Policy Implications ................................................................... 6-5 

6.1.6 The Contribution of OCS Oil and Natural Gas .................................................................................... 6-5 

6.1.6.1 Ability of OCS Production to Fulfill Short-term Needs.............................................................. 6-6 

6.1.6.2 Importance of OCS Production................................................................................................... 6-7 

6.2 Regional Energy Markets and the Location of OCS Regions ...................................................6-7 

6.2.1 Regional Production and Consumption................................................................................................ 6-8 

6.2.2 Regional Transportation..................................................................................................................... 6-10 

6.2.3 Regional Energy Prices ...................................................................................................................... 6-12 

6.2.4 Alaska Regional Energy Markets....................................................................................................... 6-13 

6.2.5 Pacific Regional Energy Markets....................................................................................................... 6-13 

6.2.6 Gulf of Mexico Regional Energy Markets ......................................................................................... 6-14 

6.2.7 Atlantic Regional Energy Markets ..................................................................................................... 6-14 

6.3 Possible OCS Production Substitutes ......................................................................................6-14 

6.4 Energy Markets Conclusion ....................................................................................................6-15 

6.5 Other Uses of the OCS ............................................................................................................6-16 

6.5.1 Alaska Region .................................................................................................................................... 6-17 

6.5.1.1 Commercial, Recreational, and Subsistence Uses..................................................................... 6-17 

6.5.1.2 Military and NASA Uses .......................................................................................................... 6-20 

6.5.1.3 Renewable Energy .................................................................................................................... 6-20 

6.5.1.4 Non-energy Marine Minerals.................................................................................................... 6-20 

6.5.2 Pacific Region .................................................................................................................................... 6-21 

6.5.2.1 Commercial, Recreational, and Subsistence Uses..................................................................... 6-21 

6.5.2.2 Military Uses............................................................................................................................. 6-22 

6.5.2.3 Renewable Energy .................................................................................................................... 6-22 

6.5.2.4 Non-Energy Marine Minerals ................................................................................................... 6-23 

6.5.3 Gulf of Mexico Region ...................................................................................................................... 6-25 

6.5.3.1 Commercial, Recreational, and Subsistence Uses..................................................................... 6-25 

6.5.3.2 Military Uses............................................................................................................................. 6-26 

6.5.3.3 Renewable Energy .................................................................................................................... 6-26 

6.5.3.4 Non-Energy Marine Minerals ................................................................................................... 6-27 

6.5.4 Atlantic Region .................................................................................................................................. 6-28 

6.5.4.1 Commercial, Recreational, and Subsistence Uses..................................................................... 6-28 

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6.5.4.2 Military and NASA Uses .......................................................................................................... 6-29 

6.5.4.3 Renewable Energy .................................................................................................................... 6-30 

6.5.4.1 Non-Energy Marine Minerals ................................................................................................... 6-33 

Chapter 7 Environmental Consideration Factors and Concerns..................................................7-1 

7.1 Environmental Setting and Ecological Characteristics..............................................................7-1 

7.1.1 Alaska Region ...................................................................................................................................... 7-2 

7.1.1.1 Arctic .......................................................................................................................................... 7-3 

7.1.1.2 Bering Sea................................................................................................................................... 7-7 

7.1.1.3 Gulf of Alaska............................................................................................................................. 7-9 

7.1.2 Pacific Region .................................................................................................................................... 7-11 

7.1.3 Gulf of Mexico Region ...................................................................................................................... 7-20 

7.1.4 Atlantic Region .................................................................................................................................. 7-24 

7.2 Potential Impacts on Environmental Resources ......................................................................7-31 

7.2.1 Accidental Oil Spills .......................................................................................................................... 7-34 

7.2.1.1 Accidental Small (≥ 1 to < 1,000 bbl) and Large (≥ 1,000 bbl) Spills...................................... 7-34 

7.2.1.2 Catastrophic Discharge Events ................................................................................................. 7-34 

7.3 Relative Environmental Sensitivity and Marine Productivity .................................................7-37 

7.3.1 Summary of Methodology ................................................................................................................. 7-37 

7.3.2 Relative Environmental Sensitivity.................................................................................................... 7-38 

7.3.2.1 Background ............................................................................................................................... 7-38 

7.3.2.2 Methods .................................................................................................................................... 7-38 

7.3.2.3 Geographic Scope ..................................................................................................................... 7-39 

7.3.2.4 Selection of Impacts, Species, and Habitats.............................................................................. 7-43 

7.3.2.5 Impact-independent Modifiers .................................................................................................. 7-45 

7.3.2.6 Results and Discussion.............................................................................................................. 7-50 

7.3.3 Marine Productivity ........................................................................................................................... 7-51 

7.3.3.1 Background ............................................................................................................................... 7-51 

7.3.3.2 Methods .................................................................................................................................... 7-52 

7.3.3.3 Results and Discussion.............................................................................................................. 7-53 

Chapter 8 Equitable Sharing Considerations .................................................................................8-1 

8.1 Definition and Introduction .......................................................................................................8-1 

8.1.1 Consideration of Elements Beyond the Secretary’s Control ................................................................ 8-2 

8.2 Regional Benefits and Risks......................................................................................................8-3 

8.2.1 Regional Benefits ................................................................................................................................. 8-3 

8.2.1.1 Additional Jobs and Increased Wages......................................................................................... 8-3 

8.2.1.2 Increased Tax Collection ............................................................................................................ 8-5 

8.2.1.3 Revenue Sharing ......................................................................................................................... 8-6 

8.2.1.4 Proximity of Energy.................................................................................................................... 8-7 

8.2.2 Regional Risks ..................................................................................................................................... 8-8 

8.3 Widely Distributed Benefits and Risks......................................................................................8-9 

8.3.1 Widely Distributed Benefits................................................................................................................. 8-9 

8.3.2 Widely Distributed Risks ................................................................................................................... 8-11 

8.4 Impacts on Benefits and Risks in the Absence of Leases in a National OCS Program...........8-12 

8.5 Summary..................................................................................................................................8-12 

Chapter 9 Industry Interest and Laws, Goals, and Policies of Affected States ...........................9-1 

9.1 Industry Interest.........................................................................................................................9-1 

9.2 Laws, Goals, and Policies of Affected States ............................................................................9-2 

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9.2.1 OCS Governors Coalition .................................................................................................................... 9-4 

9.2.2 Alaska Region ...................................................................................................................................... 9-5 

9.2.3 Pacific Region States............................................................................................................................ 9-6 

9.2.4 Gulf of Mexico Region States.............................................................................................................. 9-8 

9.2.5 Atlantic Region States.......................................................................................................................... 9-9 

Chapter 10 Assurance of Fair Market Value..................................................................................10-1 

10.1 Timing of OCS Lease Sales and Related Activities ................................................................10-2 

10.1.1 Information and Uncertainty .............................................................................................................. 10-3 

10.1.1.1 Option Value............................................................................................................................. 10-3 

10.1.1.2 Considering Uncertainties for the National OCS Program ....................................................... 10-5 

10.1.1.3 Resource Uncertainty................................................................................................................ 10-6 

10.1.1.4 Capital and Operating Cost and Extractive Technology Uncertainty ....................................... 10-8 

10.1.1.5 Environmental and Social Cost Uncertainty ............................................................................. 10-9 

10.1.1.6 Regulatory and Legal Environment Uncertainty..................................................................... 10-12 

10.1.1.7 Price Uncertainty..................................................................................................................... 10-12 

10.1.2 Hurdle Prices.................................................................................................................................... 10-13 

10.2 Leasing Framework ...............................................................................................................10-16 

10.2.1 Size of a Lease Sale.......................................................................................................................... 10-16 

10.2.2 Frequency of Lease Sales................................................................................................................. 10-17 

10.3 Other Components of FMV...................................................................................................10-17 

10.3.1 Bidding Systems............................................................................................................................... 10-17 

10.3.2 Fiscal and Lease Terms.................................................................................................................... 10-18 

10.3.2.1 Minimum Bid and Bonus Bid Amounts.................................................................................. 10-19 

10.3.2.2 Rentals .................................................................................................................................... 10-20 

10.3.2.3 Royalties ................................................................................................................................. 10-20 

10.3.2.4 Primary Term.......................................................................................................................... 10-21 

10.3.2.5 Bid Adequacy.......................................................................................................................... 10-21 

10.4 Conclusion.............................................................................................................................10-22 

Chapter 11 Glossary..........................................................................................................................11-1 

Chapter 12 References ......................................................................................................................12-1 

Appendix A: Summariesof Public Comments....................................................................................A -1

Appendix B: Economic Analysis Methodology for the 2019–2024 National Outer Continental Shelf 

Oil and Gas Leasing Draft Proposed Program...........................................................B -1 

List of Tables 

Table 1: 2019–2024 Draft Proposed Program Lease Sale Schedule............................................................8 

Table 1-1: NEPA Assessments Typically Conducted for the OCS Oil and Gas Leasing Program........1-13 

Table 4-1: Acreages of the OCS Regions .................................................................................................4-2 

Table 4-2: Status of Areas Withdrawn from OCS Oil and Gas Leasing...................................................4-3 

Table 5-1: Unleased UERR as of July 2019, Ranked by BOE for the $100 Oil Price Case...................5-13 

Table 5-2: Development of Oil and Gas Exploration and Development Scenarios................................5-15 

Table 5-3: Ranking of Planning Areas by $100/bbl Oil Price Case Net Social Value for Unleased UERR 

as of July 2019 .......................................................................................................................5-25 

Table 6-1: 2016 Petroleum Product Shipments by Tanker, Pipeline, Barge and Rail (million barrels) .6-11 

Table 6-2: 2016 Crude Oil Shipments by Tanker, Pipeline, Barge and Rail (million barrels) ...............6-12 

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Table 6-3: Other Uses of the OCS within the Alaska Region.................................................................6-18 

Table 6-4: Other Uses of the OCS within the Pacific Region.................................................................6-21 

Table 6-5: Other Uses of the OCS within the Gulf of Mexico Region...................................................6-25 

Table 6-6: Other Uses of the OCS within the Atlantic Region...............................................................6-28 

Table 7-1: BOEM Ecoregions and Alaska Planning Areas ......................................................................7-3 

Table 7-2: Potential for Program Activity Stressors to Impact Environmental Resource Receptors .....7-32 

Table 7-3: Number of Wells Compared to Loss of Well Control Events per OCS Region (1964–2015) ..... 

...............................................................................................................................................7-35 

Table 7-4: Annual Maximum OCS Spill Sizes for all Ongoing OCS Activities and OCS Planning Areas 

Combined...............................................................................................................................7-36 

Table 7-5: Crosswalk of BOEM Ecoregions and Planning Areas ..........................................................7-42 

Table 7-6: Species Selected that Differ from the Original Environmental Sensitivity Analysis (BOEM 

2014) ......................................................................................................................................7-46 

Table 7-7: Scoring of Anticipated Ecosystem Change Impacts for BOEM Ecoregions.........................7-49 

Table 7-8: Environmental Sensitivity Score by BOEM Ecoregion ........................................................7-50 

Table 7-9: Net Primary Productivity Rates.............................................................................................7-55 

Table 8-1: FY 2016 Employment Associated with OCS Oil and Gas Development................................8-4 

Table 8-2: FY 2016 8(g) and GOMESA State Disbursement Summary ..................................................8-7 

Table 9-1: Summary of Energy Exploration and Production Industry Comments on the RFI.................9-1 

Table 9-2: RFI Comment Summaries from Governor and State Agencies...............................................9-2 

Table 10-1: NSV Hurdle Prices ............................................................................................................10-15 

List of Figures 

Figure 1: 2019–2024 Draft Proposed Program Alaska Region Program Areas ..........................................9 

Figure 2: 2019–2024 Draft Proposed Program Pacific, Gulf of Mexico, and Atlantic Region Program 

Areas ...........................................................................................................................................9 

Figure 3: Alaska Region Exclusion Option Areas.....................................................................................12 

Figure 4: Gulf of Mexico Region Exclusion Option Areas.......................................................................12 

Figure 5: Atlantic Region Exclusion Option Areas...................................................................................13 

Figure 1-1: OCS and EEZ Boundaries for Alaska and the Lower 48 States ............................................1-3 

Figure 1-2: OCS Alaska Planning Areas ..................................................................................................1-4 

Figure 1-3: OCS Lower 48 States Planning Areas....................................................................................1-4 

Figure 1-4: Historical and Forecasted U.S. Crude Oil Production............................................................1-8 

Figure 1-5: Historical and Forecasted U.S. Natural Gas Production ........................................................1-8 

Figure 1-6: National OCS Oil and Gas Leasing Program and Development Process ............................1-12 

Figure 3-1: Request for Information Comment Letters by Commenter Category....................................3-2 

Figure 5-1: Extent of Geologic Plays in the Beaufort Sea and Chukchi Sea Planning Areas...................5-3 

Figure 5-2: Extent of Geologic Plays in the North Aleutian Basin Planning Area...................................5-3 

Figure 5-3: Extent of Geologic Plays in the Cook Inlet and Gulf of Alaska Planning Areas...................5-4 

Figure 5-4: Extent of Geologic Plays in the Pacific Region Planning Areas............................................5-4 

Figure 5-5: Extent of Geologic Plays in the Gulf of Mexico Region Planning Areas..............................5-5 

Figure 5-6: Extent of Geologic Plays in the Atlantic Region Planning Areas..........................................5-5 

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Figure 5-7: Risked versus Undiscovered Resource Potential for the Atlantic OCS .................................5-7 

Figure 5-14: Environmental and Social Costs by Planning Area (Ranked by $100/bbl Oil Price Case)5-21 

Figure 7-8: Pacific Region Critical Habitat for Killer Whale, Marbled Murrelet, and Black Abalone......... 

Figure 5-8: Assessment of UTRR on the OCS, 2016 ...............................................................................5-9 

Figure 5-9: Conceptual Workflow Showing Transition from UTRR to Anticipated Production...........5-10 

Figure 5-10: Unleased UERR by Planning Area ($100 Oil Price Case).................................................5-12 

Figure 5-11: Unleased UERR by Planning Area ($100 Oil Price Case).................................................5-14 

Figure 5-12: Components of the DPP Net Social Value Analysis..........................................................5-17 

Figure 5-13: Net Economic Value Ranges by Planning Area (Ranked by $100/bbl Oil Price Case).....5-18 

Figure 5-15: Net Social Value Ranges by Planning Area (Ranked by $100/bbl Oil Price Case)...........5-23 

Figure 6-1: U.S. Crude Oil Imports by Grade...........................................................................................6-3 

Figure 6-2: Historical and Forecasted U.S. Energy Consumption by Fuel Type......................................6-4 

Figure 6-3: Petroleum Administration Defense Districts..........................................................................6-8 

Figure 6-4: Contribution to Oil Production by PADD..............................................................................6-9 

Figure 6-6: Contribution to Marketed Natural Gas Production by PADD ...............................................6-9 

Figure 6-5: Oil Consumption by PADD ...................................................................................................6-9 

Figure 6-7: Natural Gas Consumption by PADD .....................................................................................6-9 

Figure 6-8: U.S. Refining Capacity by PADD, 2016..............................................................................6-10 

Figure 6-9: U.S. Crude Oil and Petroleum Production and Import/Export by Region, 2016 .................6-11 

Figure 6-10: Pacific Region Renewable Energy Planning Activities and Project Lease Area ...............6-24 

Figure 6-11: Gulf of Mexico Region Sand Borrow Areas and Significant Sand Resources ..................6-27 

Figure 6-12: Current and Proposed Renewable Energy Projects on the Atlantic OCS ..........................6-31 

Figure 7-1: NOAA Large Marine Ecosystems and BOEM Alaska Planning Areas.................................7-2 

Figure 7-2: Predominant Currents in the Beaufort and Chukchi Seas ......................................................7-4 

Figure 7-3: Beaufort Sea and Chukchi Sea Critical Habitat .....................................................................7-5 

Figure 7-4: Bering Sea Critical Habitat ....................................................................................................7-9 

Figure 7-5: Gulf of Alaska Critical Habitat ............................................................................................7-11 

Figure 7-6: NOAA Large Marine Ecosystems and BOEM Pacific Planning Areas...............................7-13 

Figure 7-7: Pacific Region Critical Habitat for Green Sturgeon and California Red-legged Frog.........7-15 

...............................................................................................................................................7-16 

...............................................................................................................................................7-17 

Figure 7-9: Pacific Region Critical Habitat for Eulachon, Leatherback Sea Turtle, and Steller Sea Lion.... 

Figure 7-10: Pacific Region Critical Habitat for Salmon and Steelhead ................................................7-18 

Figure 7-11: Pacific Region Critical Habitat for Western Snowy Plover and Tidewater Goby .............7-19 

Figure 7-12: NOAA Large Marine Ecosystem and BOEM Gulf of Mexico Planning Areas.................7-20 

Figure 7-13: Gulf of Mexico Critical Habitat for Mississippi Sandhill Crane, Piping Plover, Whooping 

Crane, Florida Manatee, and Elkhorn and Staghorn Coral ....................................................7-23 

...............................................................................................................................................7-23 

Figure 7-14: Gulf of Mexico Critical Habitat for Gulf Sturgeon, Beach Mice, and Loggerhead Sea Turtle 

Figure 7-15: NOAA Large Marine Ecosystems and BOEM Atlantic Planning Areas...........................7-25 

Figure 7-16: Atlantic Region Critical Habitat for Coral, Seagrass, North Atlantic Right Whale, and 

Piping Plover..........................................................................................................................7-29 

Figure 7-17: Atlantic Region Critical Habitat for Manatee and Loggerhead Turtles .............................7-30 

Figure 7-18: Environmental Sensitivity Score Methodology .................................................................7-39 

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Figure 7-19: Relative Environmental Sensitivity for the Alaska Region Planning Areas......................7-40 

Figure 7-20: Relative Environmental Sensitivity of Lower 48 States Planning Areas...........................7-40 

Figure 7-21: Aggregated Sensitivity Scores for Habitats, Species, and Ecosystem Change by Planning 

Area........................................................................................................................................7-51 

Figure 7-22: Marine Annual Net Primary Productivity ..........................................................................7-54 

Figure 8-1: Nominal Average Hourly Earnings of U.S. Workers.............................................................8-5 

Figure 9-1: Coastal State Governor or State Agency Responses to Request for Information ..................9-4 

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Abbreviations and Acronyms 

§ 

2-D 

3-D 

2016 National Assessment 

2019–2024 Program 

AEO 

Agreement 

Area-wide Leasing Study 

Area ID 

bbl 

BBO 

BBOE 

BOE 

BOEM 

BSEE 

Call 

California I 

California II 

CDE 

CSE 

CY 

CZM 

D.C. 

Department 

DMME 

DOD 

DPP 

DPS 

E&D 

EA 

Economic Inventory Report 

EEZ 

EIA 

EIS 

ENSO 

E.O. 

ESA 

Section 

two-dimensional 

three-dimensional 

Assessment of Undiscovered Oil and Gas Resources of the Nation’s 

Outer Continental Shelf, 2016 

2019–2024 National OCS Oil and Gas Leasing Program 

Annual Energy Outlook 

Agreement between the United States of America and the United 

Mexican States Concerning Transboundary Hydrocarbon Reservoirs in 

the Gulf of Mexico 

Policies to Affect the Pace of Leasing and Revenues in the Gulf of 

Mexico 

Area Identification 

barrels of oil 

billion barrels of oil 

billion barrels of oil equivalent 

barrel of oil equivalent 

Bureau of Ocean Energy Management 

Bureau of Safety and Environmental Enforcement 

Call for Information and Nominations 

California v. Watt, 688 F.2d 1290 (D.C. Cir. 1981) 

California v. Watt, 712 F.2d 584 (D.C. Cir. 1983) 

catastrophic discharge event 

Center for Sustainable Economy, 779 F.3d 588 (D.C. Cir. 2015) 

calendar year 

Coastal Zone Management 

District of Columbia 

United States Department of the Interior 

Virginia Department of Mines, Minerals, and Energy 

Department of Defense 

Draft Proposed Program 

distinct population segment 

exploration and development scenario 

environmental assessment 

Economic Inventory of Environmental and Social Resources Potentially 

Impacted by a Catastrophic Discharge Event within OCS Regions 

Exclusive Economic Zone 

Energy Information Administration 

environmental impact statement 

El Niño-Southern Oscillation 

Executive Order 

Endangered Species Act of 1973 

Abbreviations and Acronyms ix January 2018 
 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

ESI environmental sensitivity index 

ESP Environmental Studies Program 

ESPIS Environmental Studies Program Information System 

FMV fair market value 

FY fiscal year 

G&G geological and geophysical 

GDP gross domestic product 

GHG greenhouse gas 

GIS geographic information system 

GOM Gulf of Mexico 

GOMESA Gulf of Mexico Energy Security Act of 2006 

GRASP Geologic Resource Assessment Program 

IPF impact-producing factor 

LME Large Marine Ecosystem 

LWCF Land and Water Conservation Fund 

MAB Mid-Atlantic Bight 

MarketSim Market Simulation Model 

mcf thousand cubic feet 

MMP Marine Minerals Program 

MMPA Marine Mammal Protection Act 

MMS Minerals Management Service 

MW megawatt 

National OCS Program OCS Oil and Gas Leasing Program 

NASA National Aeronautics and Space Administration 

NEPA National Environmental Policy Act of 1969 

NEV net economic value 

nm nautical miles 

NMFS National Marine Fisheries Service 

NMS National Marine Sanctuary 

NOAA National Oceanic and Atmospheric Administration 

NOI Notice of Intent 

Northeast LME Northeast Continental Shelf LME 

NOS Notice of Sale 

NP national park 

NPP net primary productivity 

NS national seashore 

NSV net social value 

NWR national wildlife refuge 

OCS Outer Continental Shelf 

OECM Offshore Environmental Cost Model 

OPAREA Operational Area 

P.L. Public Law 

PADD Petroleum Administration for Defense District 

Programmatic EIS Programmatic Environmental Impact Statement 

Abbreviations and Acronyms x January 2018 
 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

PFP Proposed Final Program 

RCW Revised Code of Washington 

RFI Request for Information and Comments 

ROD Record of Decision 

SAB South Atlantic Bight 

SCB Southern California Bight 

Secretary Secretary of the Interior 

Southeast LME Southeast Continental Shelf LME 

TAPS Trans-Alaska Pipeline System 

Tcf trillion cubic feet 

t C km-2 yr-1 metric tons of carbon per square kilometer per year 

UERR undiscovered economically recoverable resources 

U.S. United States 

U.S.C. United States Code 

USDOI United States Department of the Interior 

USFWS United States Fish and Wildlife Service 

USGS United States Geological Survey 

UTRR undiscovered technically recoverable resources 

VGPM Vertically Generalized Production Model 

WEB3 When Exploration Begins, version 3 

Abbreviations and Acronyms xi January 2018 
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USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Overview 

Management of the oil and gas resources of the Outer Continental Shelf (OCS) is governed by the OCS 

Lands Act (43 U.S. Code [U.S.C.] 1331 et seq.), which sets forth procedures for leasing, exploration, 

development, and production of those resources. Section 18 of the OCS Lands Act (43 U.S.C. 1344) calls 

for the preparation of a nationwide OCS oil and gas leasing program, setting forth a five-year schedule of 

lease sales designed to best meet the Nation’s energy needs. The Bureau of Ocean Energy Management 

(BOEM) within the U.S. Department of the Interior (USDOI) is responsible for implementing the 

requirements of the OCS Lands Act related to preparing the leasing program. 

BOEM is in the process of preparing a national OCS oil and gas leasing program (generally referred to as 

the National OCS Program; also known as the Five-Year Program) for 2019–2024 to replace the current 

2017–2022 National OCS Oil and Gas Leasing Program. Throughout this document, you will see the 

2019–2024 National OCS Oil and Gas Leasing Program title shortened to the 2019–2024 Program and 

past National OCS Programs referred to as a variation of this short-hand (e.g., 2007–2012 Program). This 

Draft Proposed Program (DPP) for OCS oil and gas leasing is the first in a series of three decision 

documents developed, pursuant to the OCS Lands Act, before the Secretary of the Interior (Secretary) 

may take final action to approve a 2019–2024 Program (43 U.S.C. 1331 et seq.). 

This DPP phase provides a basis for conducting further analysis and a mechanism for gathering additional 

information for the Secretary to consider in making future decisions. See Chapter 1, OCS Oil and Gas 

Leasing Program Development Process, for further information regarding the OCS oil and gas leasing 

program development process. This DPP consists of the following parts: 

Part I: Draft Proposal on the Size, Timing, and Location of OCS Lease Sales presents the lease sale 

schedule and program areas proposed to be included in the 2019–2024 Program, along with the Program 

Options that BOEM prepared based on its analysis of the 26 OCS planning areas and OCS Lands Act 

Section 18 criteria. This section also describes the rationale behind the Secretary’s DPP proposal. 

Part II: Regulatory Framework describes the framework for developing a new National OCS Program. 

It discusses the substantive and procedural requirements that are in place for preparing a National OCS 

Program under Section 18 of the OCS Lands Act and describes BOEM’s approach to meeting those 

requirements. This includes a discussion of the Section 18 factors relating to OCS oil and natural gas 

resources and environmental, economic, and social considerations that Section 18 requires be taken into 

account in deciding where and when to propose lease sales. Also included is a summary of the judicial 

guidance from the court decisions regarding the National OCS Program. 

Part III: Analysis and Results presents the Section 18 analyses of all 26 OCS planning areas. BOEM 

prepared and used the Section 18 analyses to develop the Program Options presented to the Secretary. 

Appendix A: Summaries of Public Comments contains summaries of the comments BOEM received 

in response to its July 3, 2017, Federal Register Notice (82 FR 30886) requesting comments from all 

interested parties. 

Overview xii January 2018 
 

 

 

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Appendix B: Economic Analysis Methodology provides a further explanation of the analytic approach 

used for the analyses presented in Part III, including an explanation of the calculations and assumptions in 

the net social value analysis described in Section 5.3 and the fair market value analysis discussed in 

Chapter 10. 

Overview xiii January 2018 
Part I: Draft Proposal on the Size, 

Timing, and Location of OCS Lease Sales 
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2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program January 2018 

2019–2024 National OCS Oil and Gas Leasing Draft Proposal on the 

Size, Timing, and Location of Sales 

Proposal Framework 

Section 18 of the Outer Continental Shelf (OCS) 

Lands Act charges the Secretary of the Interior 

(Secretary) to perform a regional comparison 

between OCS regions and select the timing and 

location of OCS leasing so as to balance, to the 

maximum extent practicable, the potential for 

environmental damage, the potential for the 

discovery of oil and gas, and the potential for 

adverse impact on the coastal zone. 

The development of a new National OCS 

Program at this time is a key aspect of the 

implementation of President Donald Trump’s 

America-First Offshore Energy Strategy, as 

outlined in the President’s Executive 

Order (E.O.) 13795 (April 28, 2017), and 

Secretarial Order 3350 (May 1, 2017). 

E.O. 13795 states that it is “the policy of the 

United States to encourage energy exploration 

and production, including on the Outer 

Continental Shelf, in order to maintain the 

Nation’s position as a global energy leader and 

foster energy security and resilience for the 

benefit of the American people, while ensuring 

that any such activity is safe and environmentally 

responsible.” Secretarial Order 3350 calls for the 

enhancement of opportunities for energy 

exploration, leasing, and development of the 

OCS, establishment of regulatory certainty for 

OCS activities, and enhancement of conservation 

stewardship, thereby providing jobs, energy 

security, and revenue for the American people. 

This Draft Proposed Program (DPP) would make 

more than 98 percent of the OCS available to 

consider for oil and gas leasing during the 

2019–2024 period. Including at this stage nearly 

the entire OCS for potential oil and gas discovery 

is consistent with advancing the goal of moving 

the United States from simply aspiring for energy 

independence to attaining energy dominance. 

This DPP allows for consideration of 

unprecedented increases in access to America’s 

extensive offshore oil and gas resources, a 

critical component of the Nation’s energy 

portfolio, and emphasizes the importance of 

producing American energy in America. 

The potential oil and gas resources that may be 

made available as a result of this DPP are 

fundamental to America’s energy security in the 

coming decades. Development of OCS oil and 

gas is a long-term endeavor. Production from 

exploration and development in newly available 

OCS areas will likely not occur for a decade or 

more, and then will continue for another 30 to 

40 years or longer. The 2019–2024 National 

OCS Oil and Gas Leasing Program 

(2019–2024 Program) will provide the foundation 

for the Nation’s energy supply well into the 

middle of this century. 

This DPP will enable the Secretary to receive 

information necessary to conduct a thorough 

consideration of the Section 18(a)(2) factors to 

achieve the balance required by 

Section 18(a)(3) of the OCS Lands Act. Including 

areas in the 2019–2024 Program will incentivize 

industry to look to the shores of the United States 

when considering long-term investment 

strategies in upstream energy development. It 

will encourage industry to employ their worldclass geological and technical expertise to 

assess and evaluate America’s potential offshore 

oil and gas resources. By not prematurely 

restricting or narrowing OCS areas under 

consideration, this DPP will allow industry the 

opportunity to further inform the Secretary of their 

interest in leasing frontier areas and to collect 

data in areas that have not been explored in 

decades, if ever. This will, in turn, further our 

understanding of the resources available on the 

OCS to meet national energy needs. The 

Secretary’s approach to the DPP lease sale 

schedule does not prematurely foreclose 

exploration planning, but fosters it, to allow for 

the potential discovery of oil and gas on the OCS. 

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2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program January 2018 

Allowing for the potential discovery of new oil and 

gas reserves on the OCS is consistent with the 

Administration’s America-First Energy Strategy, 

which seeks to achieve energy security and 

resilience by reducing U.S. reliance on imported 

energy. Additionally, OCS oil and gas production 

benefits the United States by helping to 

reinvigorate American manufacturing and job 

growth, and contributes to the gross domestic 

product. Many of the jobs in the oil and gas 

industry earn a significant wage premium; these 

employees have more purchasing power and can 

consume more goods and services, increasing 

their standard of living, and contributing more to 

the economy. 

A vast majority of the revenues from OCS 

production accrue to the U.S. Treasury to be 

used as Congress and the President deem 

appropriate, and a smaller portion is appropriated 

to the Historic Preservation Fund and Land and 

Water Conservation Fund. The Historic 

Preservation Fund provides Federal grants to 

non-Federal entities for historic preservation 

projects and to individuals to preserve properties 

on the National Register of Historic Places. The 

Land and Water Conservation Fund provides 

matching grants to state and local governments 

for the acquisition and development of public 

outdoor recreation areas and facilities, and funds 

Federal acquisition of land and water and 

easements of such, thereby emphasizing 

recreation and protection of natural treasures, 

such as parks and forests. Further, under 

Section 8(g) of the OCS Lands Act and the Gulf 

of Mexico Energy Security Act, (Pub.L., 109-432 

[2006]), significant revenues from OCS oil and 

gas production go to adjacent coastal states. 

Although OCS oil and gas exploration and 

development will never be totally risk-free, since 

the 2010 Deepwater Horizon blowout and oil spill, 

the U.S. Department of the Interior (USDOI) has 

made, and is continuing to make, substantial 

reforms to improve the safety and reduce the 

possible adverse environmental impacts of OCS 

oil and gas activity. Working with many diverse 

stakeholders, USDOI has developed and 

implemented reforms and improvements 

designed to reduce the risk of another loss of well 

control in our oceans, and enhance our collective 

ability to respond to such incidents. 

Grounded in the above principles, and after 

careful consideration of public input and the OCS 

Lands Act Section 18(a)(2) factors, the DPP 

proposes a lease sale schedule of 47 lease sales 

in all four OCS regions and includes 25 of the 

26 planning areas: 19 lease sales in the Alaska 

Region (3 in the Chukchi Sea, 3 in the Beaufort 

Sea, 2 in Cook Inlet, and 1 sale each in the 

11 other available planning areas in Alaska), 

7 lease sales in the Pacific Region (2 each for 

Northern California, Central California, and 

Southern California, and 1 for 

Washington/Oregon), 12 lease sales in the Gulf 

of Mexico (GOM) Region (10 regionwide lease 

sales for the portions of the Central, Western, 

and Eastern GOM planning areas that are not 

currently under moratorium, and 2 sales for the 

portions of the Central and Eastern GOM 

planning areas that will no longer be under 

moratorium in 2022), and 9 lease sales in the 

Atlantic Region (3 sales each for the Mid- and 

South Atlantic, 2 for the North Atlantic, and 1 for 

the Straits of Florida). 

The DPP does not include a sale in the North 

Aleutian Basin Planning Area. This area was 

withdrawn on December 16, 2014, from 

consideration for any oil and gas leasing for a 

time period without specific expiration. 

For each OCS region, these lease sales are 

described as Option 1 below. Option 1 provides 

the greatest potential for the discovery of OCS oil 

and gas resources because almost all of the 

planning areas would be made available for lease 

sales. Particularly in the mature GOM Region, 

Option 1 allows flexibility for industry, including 

allowing frequent opportunities to bid on rejected, 

relinquished, or expired blocks. 

This DPP allows for maximum flexibility so that 

areas considered for leasing may be narrowed at 

later stages of the Section 18 process, after 

further environmental analysis and important 

input and coordination with key stakeholders. As 

of now, trade associations have expressed 

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2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program January 2018 

interest in leasing in all of the OCS regions and 

only a few exploration and production companies 

have responded. This DPP will allow the 

Secretary to obtain additional information on 

actual industry interest in obtaining leases in the 

particular planning areas. Consideration of 

industry interest in particular planning areas, 

along with all of the other Section 18(a)(2) factors 

in the OCS Lands Act, will allow for a more 

thorough comparison of OCS areas and will 

assist the Secretary in the Section 18(a)(3) 

balancing required to finalize his choice of the 

time, size, and location of the lease sales to be 

scheduled in the 2019–2024 Program. 

The Secretary is committed to enhancing 

coordination and collaboration with other 

governmental entities to discover solutions to 

multiple use challenges so that oil and gas 

resources can be discovered and extracted, 

critical military and other ocean uses can 

continue, and our sensitive physical and 

biological resources are protected. The 

Secretary’s goal is to increase access to 

America’s energy resources and to provide 

environmental stewardship based upon the most 

up-to-date environmental information and 

analysis. 

National OCS Program Decision Process 

The Bureau of Ocean Energy Management 

(BOEM) is responsible for administering the 

leasing program for oil and gas resources on the 

OCS and advising the Secretary in the National 

OCS Program. The three analytical phases 

required to develop the 2019–2024 Program 

include the (1) DPP; (2) Proposed Program; and 

(3) Proposed Final Program (PFP). The 

2019–2024 Program, once completed, will 

replace the 2017–2022 Program. 

The National OCS Program development 

process started with a Request for Information 

(RFI) that requested information on all 26 OCS 

planning areas. The RFI for the 

2019–2024 Program was announced by 

President Trump and the Secretary on 

June 29, 2017. The RFI officially published in the 

Federal Register on July 3, 2017. The comment 

period closed on August 17, 2017, and BOEM 

received approximately 816,000 comments from 

a host of stakeholders including governors, 

Federal agencies, state agencies, local agencies, 

energy and non-energy industries, tribal 

governments, non-governmental organizations 

including environmental advocacy groups, and 

the general public (see Appendix A for more 

information). Comments received in response to 

the RFI ranged from supporting exploration and 

development of the entire OCS to prohibiting any 

such exploration and development at all. 

This DPP is the first in a series of three 

preliminary proposals made by the Secretary 

consistent with the OCS Lands Act, before he 

may take final action to approve a 

2019–2024 Program. The OCS Lands Act also 

requires the Secretary to consider nominations of 

areas to be excluded from leasing. Inclusion of 

an area at the DPP phase is not a final indication 

that it will be included in the approved 

2019–2024 Program or offered in a lease sale, 

because decision points still remain for reducing 

or completely removing an area or sale. 

However, any area or sale that is not included in 

this DPP stage will not be further considered. 

The DPP phase also acts as a mechanism to 

gather additional information for the Secretary to 

consider in making future decisions in the 

Section 18 process. Now that the Secretary has 

proposed this DPP, public comments are being 

solicited (see Chapter 3). These comments will 

be considered during the next stage of 2019– 

2024 Program development process: the 

Proposed Program. During the Proposed 

Program stage, only those program areas and 

Program Options that the Secretary includes in 

the DPP will be further analyzed in accordance 

with Section 18. These Program Options will be 

analyzed in both the Proposed Program 

document and the associated Draft 

Programmatic Environmental Impact Statement 

(Draft Programmatic EIS). The Draft 

Programmatic EIS will analyze the potential 

environmental effects of leasing in areas included 

in the DPP and may identify areas that warrant 

consideration or exclusion from leasing in the 

3 Draft Proposal on OCS Lease Sales for 2019–2024 
 

 

 

 

 

 

 

 

 

 

 

 

2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program January 2018 

2019–2024 Program. The program areas 

identified in the Proposed Program will be 

analyzed in the PFP and the Final Programmatic 

EIS. 

Once the 2019–2024 Program has been 

approved, there are additional requirements at 

the lease sale stage for lease sale size and 

timing analyses, environmental review, and 

public comment. 

Secretarial Consideration of the Eight 

OCS Lands Act Section 18(a)(2) Factors 

This DPP represents the result of the initial 

consideration of each of the following eight 

Section 18(a)(2) factors by the Secretary. The 

public comments and information received as a 

result of this DPP will further inform the 

Secretary’s consideration of these factors and the 

eventual balancing that is performed for choosing 

the size, timing, and location of the OCS areas 

that will be considered for the potential discovery 

of oil and gas reserves. 

GEOGRAPHICAL, GEOLOGICAL, AND ECOLOGICAL 

CHARACTERISTICS 

Geographical, geological, and ecological 

characteristics are taken into account throughout 

the DPP analytical process. Where possible, 

BOEM considers recent geophysical, geological, 

and technological information to estimate the 

potential presence and amount of technically 

recoverable oil and gas resources on the OCS. 

BOEM also considers economic parameters, 

such as exploration and development costs and 

oil and gas prices, to estimate the economically 

recoverable resources on the OCS. By including 

all available areas for leasing in the DPP 

schedule, environmental analysis will be 

conducted on every area along with information 

on expected resource potential. 

Equitable Sharing 

Benefits from the development and production of 

oil and gas resources accrue primarily to 

producing regions and nearby onshore 

populations. These benefits generally include the 

following: 

• Billions of dollars a year in bonus bids, 

rentals, and royalties to the U.S. 

Treasury 

• Funding for the Historic Preservation 

Fund and Land and Water Conservation 

Fund 

• Payments to state and local governments 

pursuant to OCS Lands Act Section 8(g) 

and other revenue sharing programs 

• Contributions to the economy indirectly 

through employment, wages, and tax 

payments to state and local 

governments. 

Development and production of oil and gas 

resources associated with leasing under the 

National OCS Program involves the risk of harm 

to the human, coastal, or marine environments. 

This potential for impacts is often within the 

waters of the OCS and in the immediate coastal 

zone. Higher levels of activity often equate to 

higher level of risk of impact. Additionally, in 

areas of limited onshore development, new 

infrastructure might cause significant impacts. 

These principles of equitable sharing can best be 

assessed by not prematurely eliminating areas 

from leasing consideration. By offering leases in 

every planning area, this DPP more equitably 

shares benefits and risks among regions than 

any National OCS Program in the past 30 years. 

REGIONAL AND NATIONAL ENERGY MARKETS 

The overall need for imported oil has declined 

over the past several years given increasing 

domestic onshore production. The increased 

domestic onshore production is light sweet crude, 

whereas most oil currently imported is heavy 

crude oil. The medium-to-heavy crude oil found 

on the OCS provides a domestic source to 

replace imports. Forecasts predict that 

U.S. crude production will increase in 2017 and 

4 Draft Proposal on OCS Lease Sales for 2019–2024 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program January 2018 

that the current production record set in 1970 will 

be surpassed in 2018 (EIA 2017a). GOM 

production surpassed its previous 2009 record in 

2016, and is expected to increase through 2018. 

However, decreases in the amount of OCS 

drilling over the past several years make the 

increases unlikely to continue. Expanded access 

to the OCS provides a means for these increases 

to continue as exploration and development 

takes place in new areas. 

OCS production provides a steady and 

predictable source of oil and gas for decades and 

is less susceptible to short-term price changes 

than onshore production. Therefore, potential 

future oil and gas production from the planning 

areas considered in this DPP could help maintain 

the Nation’s position as a global energy leader for 

50 or more years into the future. Further, oil and 

gas production from planning areas considered in 

this DPP could better meet the energy demands 

in regional markets that are major energy 

consumers currently reliant on production 

imported from other regions or nations (e.g., east 

and west coast markets). 

Additionally, the Energy Information 

Administration (EIA) projects that the United 

States will continue to heavily rely on oil and 

natural gas to meet its energy needs under 

current laws and regulations. In 2016, 65 percent 

of energy consumed in the United States came 

from petroleum, other liquid hydrocarbons, and 

natural gas, and this percentage is projected to 

increase through 2050 (EIA 2017b). 

The President’s energy strategy seeks to 

encourage energy exploration and production to 

maintain the United States’ position as a global 

energy leader. Through providing opportunities 

for exploration, leasing, and development and 

establishing regulatory certainty, additional 

domestic energy production provides energy 

security, jobs, and revenue for the Nation. 

Through continued and expanded production, the 

OCS can enhance energy security by reducing 

dependence on foreign fuel sources. Further, the 

DPP addresses the need for the United States to 

continue to pursue traditional sources of energy, 

while encouraging development of renewable 

energy. Although new energy alternatives are 

gaining market share, they will take decades to 

displace oil and gas. Additionally, oil and gas are 

used to make nonfuel products, such as plastics 

and fertilizer, for which future alternatives will be 

needed. All current commercial substitutes for oil 

and gas have market penetration limits, and none 

provide the prospect of fully replacing the 

versatility of oil and gas. 

OTHER USES OF THE OCS 

In general, other uses of the OCS include 

activities related to military readiness, including 

critical military training and testing operations; 

National Aeronautical and Space Administration 

(NASA) launch operations; commercial and 

recreational fishing; tourism; subsistence fishing 

and hunting; renewable energy production; and 

shipping. USDOI is committed to working with 

other Federal agencies, state and local 

governments, and tribal organizations to 

cooperatively manage other uses of the OCS. 

This DPP reflects the Secretary’s commitment to 

continue his ongoing consultation efforts and 

weigh the input received from all interested 

stakeholders and explore ways to reduce 

conflicts before prematurely excluding OCS 

areas from further consideration. 

INDUSTRY INTEREST 

OCS Lands Act Section 18(a)(2)(E) (see 

Section 2.2) requires BOEM to consider the 

interest of potential oil and gas producers. In 

response to the RFI, BOEM received 

10 comment letters from exploration and 

development companies and associations in the 

energy industry that explore for and/or produce 

oil and gas. Of those responses, most supported 

including all 26 OCS planning areas for further 

analysis, although few expressed specific interest 

in all of the planning areas. See Chapter 9 for 

further information industry input thus far. With 

this DPP, the Secretary seeks to obtain additional 

input from industry concerning their interest in 

acquiring leases in the sales scheduled in this 

DPP. This information will allow the Secretary to 

further consider the potential for discovery of oil 

5 Draft Proposal on OCS Lease Sales for 2019–2024 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program January 2018 

and gas resources to inform the decision on the 

size, time, and location of lease sales to be 

included in the 2019–2024 Program. 

LAWS, GOALS, AND POLICIES OF AFFECTED STATES 

For 18 of the 25 planning areas included in the 

DPP, leasing has the support of at least one 

adjacent state. The Secretary’s DPP provides 

flexibility for states to provide further input and 

information about the traditionally offered areas, 

as well as those that have not been considered in 

some time during successive program 

development phases. See Chapter 9 for more 

information on input received so far from state 

governments. The input of the states, particularly 

coastal states, is given specific consideration 

when deciding which areas of the OCS will be 

included in the final National OCS Program. By 

not excluding any coastal state at this point in the 

decisionmaking, every state can further consider 

and provide input regarding the potential benefits 

and costs of leasing off its shore. State laws, 

goals, and policies may change during the 

Section 18 process. Therefore, this DPP allows 

the Secretary to further consider the laws, goals, 

and policies of coastal states prior to formulating 

his Proposed Program, without unduly limiting his 

flexibility by prematurely excluding planning 

areas from further consideration at the DPP 

stage. 

ENVIRONMENTAL SENSITIVITY AND MARINE 

PRODUCTIVITY 

Environmental sensitivity scores are a composite 

of scores for vulnerability and resilience of 

species, habitats, and potential ecosystem 

change impacts. The results from this analysis 

indicate similar sensitivities for all OCS regions. 

The regions with the highest sensitivity scores 

were the GOM and the Arctic. 

In addition, primary production forms the base of 

the marine food chain. Both the highest 

(Cook Inlet) and lowest (Arctic) productivity 

estimates were measured in the Alaska Region. 

The low values in the Arctic are attributable to 

seasonably low light availability. Protections of 

sensitive resources can often be achieved 

through mitigation, rather than outright exclusion 

from the leasing program. Leaving most areas in 

at this point in the decisionmaking allows the 

greatest flexibility to consider how high sensitivity 

or productivity and the potential for oil and gas 

productivity can best be managed. 

ENVIRONMENTAL AND PREDICTIVE INFORMATION 

The consideration of stressors and associated 

potential impacts must also include consideration 

of the potential severity of impact. The 

Programmatic EIS that will be prepared in 

connection with the development of the 

2019–2024 Program will evaluate and disclose 

potential impacts in more detail, and will identify 

and discuss impacts that could be significant and 

identify mitigation opportunities. The subsequent 

National Environmental Policy Act analyses 

prepared for this program will identify and assess 

impacts and allow those potential environmental 

concerns to be weighed against the other 

Section 18 criteria. 

Fair Market Value 

The requirement in the OCS Lands Act Section 

18(a)(4) to assure receipt of fair market value is 

met through a multi-phase process at the 

National OCS Program, lease sale, and 

leaselevel stages. 

Components are considered at the Program 

level, but subject to sale-by-sale reconsideration, 

including hurdle prices, leasing framework (size 

and frequency of lease sales), bidding systems, 

fiscal and lease terms, and bid adequacy. 

USDOI has the option to offer OCS areas for 

lease at any time in the future, and makes the 

decision whether to exercise the option based on 

multiple factors. 

If expected prices at the start of the 

2019–2024 Program (2019 barrel of oil 

equivalent price) are above the hurdle price, the 

social value of offering leases for prompt 

exploration is greater than the value of waiting 

five years. 

6 Draft Proposal on OCS Lease Sales for 2019–2024 
 

 

 

 

 

2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program January 2018 

With one exception, the expected market prices 

exceed the hurdle price in all planning areas. 

The hurdle price in the Central California 

Planning Area exceeds the expected 

2019 market price, indicating that delaying lease 

sales in this area could be beneficial from an 

option value perspective. Since market prices 

can be volatile, inclusion of an area at this early 

DPP stage provides the opportunity for additional 

analysis and consideration as the National OCS 

Program development process continues. 

2019–2024 Draft Proposed Program 

Lease Sale Schedule 

The schedule shown in Table 1 below reflects the 

lease sale options selected to create the 

2019–2024 DPP. Figures 1 and 2 depict the 

DPP program areas. 

7 Draft Proposal on OCS Lease Sales for 2019–2024 
 

 

2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program January 2018 

Table 1: 2019–2024 Draft Proposed Program Lease Sale Schedule 

Sale Year OCS Region Program Area 

1. 2019 Alaska Beaufort Sea 

2. 2020 Alaska Chukchi Sea 

3. 2020 Pacific Southern California 

4. 2020 Gulf of Mexico Western, Central, and Eastern Gulf of Mexico* 

5. 2020 Gulf of Mexico Western, Central, and Eastern Gulf of Mexico* 

6. 2020 Atlantic South Atlantic 

7. 2020 Atlantic Mid-Atlantic 

8. 2021 Alaska Beaufort Sea 

9. 2021 Alaska Cook Inlet 

10. 2021 Pacific Washington/Oregon 

11. 2021 Pacific Northern California 

12. 2021 Pacific Central California 

13. 2021 Atlantic North Atlantic 

14. 2021 Gulf of Mexico Western, Central, and Eastern Gulf of Mexico* 

15. 2021 Gulf of Mexico Western, Central, and Eastern Gulf of Mexico* 

16. 2022 Alaska Chukchi Sea 

17. 2022 Pacific Southern California 

18. 2022 Atlantic Mid-Atlantic 

19. 2022 Atlantic South Atlantic 

20. 2022 Gulf of Mexico Western, Central, and Eastern Gulf of Mexico* 

21. 2022 Gulf of Mexico Western, Central, and Eastern Gulf of Mexico* 

22. 2023 Alaska Beaufort Sea 

23. 2023 Alaska Cook Inlet 

24. 2023 Alaska Hope Basin 

25. 2023 Alaska Norton Basin 

26. 2023 Alaska St. Matthew-Hall 

27. 2023 Alaska Navarin Basin 

28. 2023 Alaska Aleutian Basin 

29. 2023 Alaska St. George Basin 

30. 2023 Alaska Bowers Basin 

31. 2023 Alaska Aleutian Arc 

32. 2023 Alaska Shumagin 

33. 2023 Alaska Kodiak 

34. 2023 Alaska Gulf of Alaska 

35. 2023 Pacific Central California 

36. 2023 Pacific Northern California 

37. 2023 Gulf of Mexico Western, Central, and Eastern Gulf of Mexico* 

38. 2023 Gulf of Mexico Western, Central, and Eastern Gulf of Mexico* 

39. 2023 Gulf of Mexico Eastern and Central Gulf of Mexico** 

40. 2023 Atlantic Straits of Florida 

41. 2023 Atlantic North Atlantic 

42. 2024 Alaska Chukchi Sea 

43. 2024 Gulf of Mexico Western, Central, and Eastern Gulf of Mexico* 

44. 2024 Gulf of Mexico Western, Central, and Eastern Gulf of Mexico* 

45. 2024 Gulf of Mexico Eastern and Central Gulf of Mexico** 

46. 2024 Atlantic South Atlantic 

47. 2024 Atlantic Mid-Atlantic 

Notes: 

* All available areas, not including those subject to the GOMESA moratorium through June 30, 2022. 

** Those areas available following the expiration of the GOMESA moratorium. 

8 Draft Proposal on OCS Lease Sales for 2019–2024 
2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program January 2018 

9 Draft Proposal on OCS Lease Sales for 2019–2024 

Figure 1: 2019–2024 Draft Proposed Program Alaska Region Program Areas 

Figure 2: 2019–2024 Draft Proposed Program Pacific, Gulf of Mexico, and Atlantic Region Program Areas 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program January 2018 

Options to be Analyzed in the 

Proposed Program 

The Program Options discussed in the following 

paragraphs have been identified for the 

Secretary’s consideration. The chosen Program 

Option for each region, as shown in Table 1, is 

indicated by bold font; however, other Program 

Options may warrant further analysis in the 

subsequent Proposed Program and Draft 

Programmatic EIS documents, as appropriate. 

Any options considered at the Proposed 

Program phase would not be greater in 

geographic scope or frequency of lease sale 

offering than the DPP Program Options 

presented in this section. In addition, a no lease 

sale option will be analyzed for all program 

areas in the Proposed Program document and 

Draft Programmatic EIS. 

ALASKA REGION PROGRAM OPTIONS 

The chosen option for the Alaska Region is 

listed below and shown in Figure 1. 

The DPP does not include a sale in the North 

Aleutian Basin Planning Area. This area was 

withdrawn on December 16, 2014, from 

consideration for any oil and gas leasing for a 

time period without specific expiration. 

Option 1: Three sales in the Beaufort Sea 

Program Area in 2019, 2021, and 2023; three 

sales in the Chukchi Sea Program Area in 

2020, 2022, and 2024; two sales in the Cook 

Inlet Program Area in 2021 and 2023; and 

one sale each in the Hope Basin, Norton 

Basin, St. Matthew-Hall, Navarin Basin, 

Aleutian Basin, St. George Basin, Bowers 

Basin, Aleutian Arc, Shumagin, Kodiak, and 

Gulf of Alaska program areas in 2023. 

Option 2: Option 1 with the exclusion of one or 

more of these five exclusion options, identified 

as having exceptional ecological or subsistence 

values, or both, as shown in Figure 3: 

1. Excluding Hanna Shoal in the Chukchi 

Sea 

2. Excluding a subsistence use area in the 

Chukchi Sea 

3. Excluding a 25-mile coastal buffer 

portion of the Chukchi Sea 

4. Excluding the Barrow Whaling Area in 

Beaufort Sea 

5. Excluding the Kaktovik Whaling Area in 

the Beaufort Sea. 

PACIFIC REGION PROGRAM OPTIONS 

See Figure 2 for a depiction of Option 1 below. 

Option 1: Two sales in the Southern 

California Program Area in 2020 and 2022, 

two sales in the Northern California Program 

Area in 2021 and 2023, two sales in the 

Central California Program Area in 2021 and 

2023 and one sale in the Washington/Oregon 

Program Area in 2021. 

GULF OF MEXICO REGION PROGRAM OPTIONS 

See Figure 2 for a depiction of Option 1 below. 

The portions of the Central and Eastern GOM 

planning areas that are currently under 

moratorium would be available for lease sale 

activities, including the initiation of the lease sale 

process, upon expiration of the Gulf of Mexico 

Energy Security Act on July 1, 2022. This is the 

first time the majority of the Eastern GOM 

Planning Area would be available for leasing 

since 1988. 

Option 1: Ten regionwide sales in the 

portions of the Western, Central and Eastern 

GOM program areas (not currently under 

moratorium) in 2020, 2021, 2022, 2023, and 

2024. Two sales in the portions of the 

Central and Eastern GOM program areas 

(under moratorium until 2022) in 2023 and 

2024. See Figure 2 for the identified 

moratorium areas. 

Option 2: Option 1 with coastal buffer(s) (see 

Figure 4 for examples) to accommodate military 

activities and nearshore use. 

10 Draft Proposal on OCS Lease Sales for 2019–2024 
 

 

 

 

 

2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program January 2018 

Option 3: Option 1 with Baldwin County buffer 

(see Figure 4). 

ATLANTIC REGION PROGRAM OPTIONS 

See Figure 1 for a depiction of Option 1 below. 

Option 1: Three sales in the Mid- and South 

Atlantic program areas in 2020, 2022, and 

2024; two sales in the North Atlantic Program 

Area in 2021 and 2023; and one sale in the 

Straits of Florida Program Area in 2023. 

Option 2: Option 1 with the exclusion of the 

Atlantic Canyons in the North Atlantic and 

Mid-Atlantic program areas, identified as having 

exceptional ecological values (see Figure 5). 

Option 3: Option 1 with coastal buffer(s) to 

accommodate concerns such as military use, 

fish and marine mammal migration, and other 

nearshore uses (see Figure 5 for an example 

coastal buffer). 

11 Draft Proposal on OCS Lease Sales for 2019–2024 
2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program January 2018 

12 Draft Proposal on OCS Lease Sales for 2019–2024 

Figure 3: Alaska Region Exclusion Option Areas 

Figure 4: Gulf of Mexico Region Exclusion Option Areas 
2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program January 2018 

Figure 5: Atlantic Region Exclusion Option Areas 

13 Draft Proposal on OCS Lease Sales for 2019–2024 
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Part II: Regulatory Framework 

Part II: Regulatory Framework 1-1 January 2018 
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Chapter 1 OCS Oil and Gas Leasing Program Development Process 

1.1 INTRODUCTION 

Section 18 of the Outer Continental Shelf (OCS) Lands Act (43 United States Code [U.S.C.] 

Section [§] 1344) requires the Secretary of the Interior (Secretary) to prepare and maintain a schedule of 

proposed OCS oil and gas lease sales (referred to as the National OCS Program, also called the Five-Year 

Program) determined to “best meet national energy needs for the five-year period following its approval 

or reapproval.” The proposed oil and gas leasing program must be prepared and maintained in a manner 

consistent with the principles and criteria specified in Section 18 of the OCS Lands Act. Those criteria, 

and the manner in which they have been considered in preparing this 2019–2024 National OCS Oil and 

Gas Leasing Draft Proposed Program, are summarized in Chapter 2. 

The OCS consists of all submerged lands, subsoil, and seabed lying between the seaward extent of the 

states’ jurisdiction and the seaward extent of Federal jurisdiction as defined in the Submerged Lands Act 

(see 43 U.S.C. §§ 1301 and 1331). The jurisdiction of the United States lies seaward of states’ 

jurisdiction, which in most cases is three miles from the coastline. However, Texas, the Gulf coast of 

Florida, and Louisiana have slightly different jurisdictional limits as a result of a court decision. The 

jurisdiction of Texas and that of Florida, off its Gulf coast, extend nine nautical miles (nm) and 

Louisiana’s jurisdiction is three imperial nm. In 1983, President Reagan proclaimed the sovereign rights 

and jurisdiction of the United States over submerged lands and seas adjacent to the United States within 

the Exclusive Economic Zone (EEZ), as recognized by international law. The EEZ extends a distance of 

200 nm from the baseline from which the breadth of the territorial sea is measured.1 Figure 1-1 shows the 

boundaries for Federal jurisdiction and the EEZ. 

Section 18 of the OCS Lands Act requires that the proposed schedule of lease sales be based upon a 

comparative analysis of the oil- and gas-bearing regions of the OCS. For administrative and planning 

purposes, the Bureau of Ocean Energy Management (BOEM) has established four OCS regions 

comprised of 26 planning areas, as shown in Figures 1-2 and 1-3. The four OCS regions are Alaska, 

Pacific, Gulf of Mexico (GOM), and Atlantic. Administratively, the Pacific Region includes the State of 

Hawaii. Hawaii does not have any OCS oil or natural gas production because of a lack of hydrocarbon 

resources; therefore, for the National OCS Program, the Pacific Region is only comprised of the four 

planning areas off the United States (U.S.) west coast. 

1 The EEZ 200-nm limit, however, does not define the outer limit of the OCS under the OCS Lands Act and could 

be better considered in that context as a jurisdictional minimum, except where constrained by the jurisdictional 

reaches of adjacent coastal nations. 

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Figure 1-1: OCS and EEZ Boundaries for Alaska and the Lower 48 States 

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Figure 1-2: OCS Alaska Planning Areas 

Figure 1-3: OCS Lower 48 States Planning Areas 

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1.2 NATIONAL ENERGY NEEDS 

Meeting national energy needs is a primary purpose of the OCS Lands Act Amendments of 1978 

(43 U.S.C. 1802), which established the criteria for the Secretary to consider when developing each new 

National OCS Program (Public Law [P.L.] 95-372). Section 18 of the OCS Lands Act was added by the 

Amendments and requires the Secretary to formulate a National OCS Program to “best meet national 

energy needs for the five-year period following its approval or reapproval” (Section 18(a), 

43 U.S.C §1344(a)).2 The National OCS Program is designed to enable the decisionmaker to consider 

national energy needs over the long-term (40–70 years into the future). Prior to lease issuance, there are 

additional decision points that allow the decisionmaker to consider new information about U.S. energy 

needs. Once leases are issued, the contribution of OCS production toward meeting national energy 

needs might not be realized for years into the future. Once realized, the impacts and benefits of OCS 

energy production for the United States will continue for decades into the future. 

Energy needs, as recognized in the language of the OCS Lands Act and reinforced by the U.S. Court of 

Appeals for the District of Columbia (D.C.) Circuit, is a broad term that includes economic and energy 

policy goals, national security, dependence on foreign sources of energy, the balance of payments in 

world trade, and other aspects of national welfare affected by the availability of appropriate quantities 

and qualities of oil and gas.3 Despite changes over the past few decades, many of the energy challenges 

that led to the passage of Section 18 still remain today, and energy continues to play a central role in the 

U.S. economy. 

OCS oil and gas production is a key component in meeting U.S. energy needs and provides valuable 

energy resources that contribute to U.S. energy security; an improved balance of payments; trade gains 

from exporting refined petroleum products; and increases in public revenues, employment, direct output, 

and value added through the supply chain. 

Developing more OCS energy production to support U.S. energy needs is a major component of the 

President’s energy strategy. Executive Order (E.O.) 13783, Promoting Energy Independence and 

Economic Growth, and E.O. 13795, The America-First Offshore Energy Strategy, together recognize the 

need for energy for American families and businesses and implement a plan to ensure energy security 

and economic vitality. E.O. 13795 provides U.S. policy to encourage domestic energy exploration and 

production to “maintain the Nation’s position as a global energy leader and foster energy security and 

resilience for the benefit of the American people.” Secretarial Order 3350 further implements the 

President’s E.O. by “enhancing opportunities for energy exploration, leasing, and development” on the 

OCS and promoting regulatory certainty for OCS activities to provide jobs, energy security, and revenue 

for the American people. The E.O.s and Secretarial Order recognize the broad nature of America’s 

energy needs and the important contribution made by OCS production. 

2 Section 18 also requires the Secretary to consider “the location of such regions [oil- and gas-bearing physiographic regions] 

with respect to, and the relative needs of, regional and national energy markets” (Section 18(a)(2)(c), 43 U.S.C. §1344(a)(2)(c)). 

Chapter 6 contains the energy markets analysis conducted to help the Secretary meet that requirement.

3 The Federal Circuit Court upheld this broad concept of energy needs in Center for Sustainable Economy v. Department of the 

Interior, 779 F.3d 588 (D.C. Cir. 2015). The court premised that “any capacity that is developed domestically helps to ensure 

that the United States has available domestic sources of fuel for domestic consumption as needed, for example, in the event of 

international conflict, natural disaster, unexpected foreign fuel shortages, or price volatility in international markets.” 

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1.2.1 Contribution of Oil and Natural Gas to the U.S. Economy 

Since 2005, American consumers have spent more than one trillion dollars a year, or generally more than 

seven percent of the gross domestic product (GDP), on energy (EIA 2017a). In 2016, oil and gas 

consumption accounted for approximately 66 percent of the energy consumed domestically, and it 

directly or indirectly supports the supply chain for delivering nearly all goods and services in our 

economy (EIA 2017b). Further, oil and gas activity contributes to employment and public revenues and 

the level of that activity affects the balance of payments and trade, energy security, and technology. 

The U.S. Geological Survey (USGS) and BOEM estimate that a significant share of U.S. remaining oil 

(69 percent) and natural gas (22 percent) resources underlie the OCS (USGS 2013, BOEM 2016). 

Therefore, OCS oil and gas production can contribute to meeting the country’s energy needs. In 

particular, the continued oil and natural gas production in the GOM, the primary OCS region currently 

available for energy production and development activities, remains vital. 

1.2.1.1 Consumption of Energy Sources 

Although U.S. energy needs expand far beyond simply consuming oil and natural gas, these fuels 

currently are fundamental to powering our economy. While oil has largely been replaced by other fuels 

for electricity generation, its dominant role as a fuel in the transportation sector is unlikely to change 

significantly in the foreseeable future because of a variety of limiting factors. Other sources of energy 

have gained less than 5 percentage points of the transportation-fuel market share since the initial price 

shocks of 1974. In 2017, petroleum still accounts for more than 92 percent of transportation fuel share 

and petroleum-based fuels account for 97 percent (EIA 2017b). Crude oil is a raw input for gasoline and 

other transportation fuels, as well as for a variety of petroleum products found in non-fuel markets 

(e.g., chemicals, plastics, synthetic materials). Section 6.2.1 provides more information on the 

consumption of oil and natural gas. 

Over the past decade, hydraulic fracturing (“fracking”), combined with horizontal drilling, has allowed 

companies to significantly increase U.S. production from shale and other tight onshore oil and gas 

formations. The increase in domestic natural gas production led to lower prices, which in turn increased 

natural gas consumption. Natural gas has low carbonemitting potential relative to coal, and is 

increasingly used for electricity generation (EIA 2015). Further, lower gas prices have reduced energy 

costs for manufacturing and allowed more companies to begin, or to increase, domestic operations 

(PwC 2011). In addition, low energy costs have allowed more companies to bring formerly overseas 

operations back to the United States, thus benefitting American workers (Boston Consulting 

Group 2012). This manufacturing renaissance has benefitted all regions of the country. Over the next 

30 years, the Energy Information Administration (EIA) expects the United States to rely on greater 

amounts of oil and natural gas to meet its energy demands, even as alternative sources of energy provide 

an increasing share of U.S. energy supply (EIA 2017c). It is important to keep in mind, however, that 

this assumption is based on current policy and technological assumptions. Changes in policy and more 

rapid technological advances could impact future markets and demand for oil and gas. 

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1.2.1.2 Balance of Payments and Trade 

The America-First Offshore Energy Strategy is designed to increase domestic oil and gas production and 

reduce dependence on imported energy. Of the U.S.’s $505 billion dollar trade deficit for all goods and 

services, the cumulative U.S. trade deficit in crude oil and petroleum products was $58 billion, or 

11 percent (BEA 2017). Recently, the portion of the trade deficit attributed to crude oil and petroleum 

products has decreased, largely due to falling prices in the oil and gas market, but also due to an increase 

in energy exports. Over the past six years, U.S. crude oil and petroleum product exports have more than 

doubled (EIA 2017d). The U.S. became a net exporter of petroleum products in 2011 and was the 

world’s largest net exporter of refined products in 2016 (EIA 2017e). While the U.S. is expected to 

remain a net importer of crude oil for the foreseeable future, current projections show U.S. aggregate 

imports and exports from all energy sources coming into balance in 2026, with the U.S. becoming a net 

exporter of natural gas in 2018 (EIA 2017c). The country’s transition away from being a net importer of 

energy will continue to improve the balance of trade. OCS production will remain an important 

contributor to domestic U.S. oil supplies, helping to further improve the trade balance. 

1.2.1.3 Energy Security 

As described in the America-First Energy Plan, domestic energy production enhances America’s 

national security interests by reducing our dependence on imported oil as well as providing domestic 

energy, particularly to the Department of Defense (DOD). The United States can reduce dependence on 

foreign oil by increasing the supply of domestic energy or by reducing domestic energy consumption. 

The recent increase in U.S. energy production has greatly contributed to U.S. energy supply security. 

The increase in domestic production has reduced the U.S. need to import foreign oil and has increased 

world production, which in turn has permitted greater foreign policy latitude and effectiveness for the 

United States (Cummings and Gold 2013, Engel and Windrem 2013). 

OCS oil and natural gas production varies considerably from year to year. The absolute amount of OCS 

oil production has increased somewhat over the past 10 years, whereas OCS natural gas production has 

fallen in the last decade, reflecting the decline in gas prices over the same period (BSEE 2017). In recent 

years, due to increased onshore production, the percentage of OCS oil and gas as a share of domestic 

production has declined and in 2016 was 18 percent for oil and 4 percent for natural gas (see Figures 1-4 

and 1-5). However, OCS production continues to provide a vital source of domestic production that can 

reduce the Nation’s vulnerability to a supply disruption. As explained in Section 6.1.6.1, the National 

OCS Program development and leasing processes provide far more flexibility to adapt to unexpectedly 

low energy needs (e.g., by reducing sale size, delaying or canceling sales) than to unexpectedly high 

needs (i.e., new sales and areas cannot be added after the National OCS Program has been approved).4 

Other components of energy security are affordability of energy supplies and reduction of price 

volatility. In the absence of artificial rationing or an especially destructive natural disaster, higher prices 

are often the only publicly visible sign of supply disruptions. Oil is sold in a competitive world market 

and a reduction in supply (or an increase in demand) in one part of the world causes higher prices 

globally. Price spikes are disruptive and damaging to the economy. 

4 In addition, while lessees can decide fairly quickly to cancel or not initiate new OCS projects on existing leases, companies 

cannot initiate new OCS projects on unleased lands without going through a long process, including planning for a lease sale, 

bidding, applying for and obtaining approvals, and determining prospect viability through exploration, a process that can take 

10–20 or more years, particularly in frontier areas. 

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Figure 1-4: Historical and Forecasted U.S. Crude Oil Production 

0% 

5% 

10% 

15% 

20% 

25% 

30% 

35% 

0 

2 

4 

6 

8 

10 

12 

1981 1990 1999 2008 2017 2026 2035 2044 

Million Barrels/Day 

Federal Offshore % of Total 

Federal Offshore 

Onshore and State 

Offshore ← Historical Forecast →

Federal Offshore 

as % of Total 

Source: EIA 2017f, EIA 2017g 

Figure 1-5: Historical and Forecasted U.S. Natural Gas Production 

0% 

5% 

10% 

15% 

20% 

25% 

30% 

0 

5 

10 

15 

20 

25 

30 

35 

40 

1980 1990 2000 2010 2020 2030 

Federal Offshore % of Total 

Trillion Cubic Feet

Federal 

Offshore 

Onshore and State 

Offshore 

← Historical Forecast →

Federal Offshore 

as % of Total 

Source: EIA 2017h, EIA 2017i 

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The EIA predicts costs for imported energy will increase in real terms over the coming decades. The 

possibility of high and volatile energy prices, which have been avoided recently due to robust domestic 

oil and gas production especially for crude oil, raises important energy policy issues about supply 

options and their effects on the economy and the environment. 

1.2.1.4 Technology 

New technologies in the oil and gas industry are, in large part, responsible for the U.S. energy revival, 

which made the U.S. the world’s top producer of petroleum and natural gas. Technological 

advancements in fracking and horizontal drilling, along with high prices, drove the recent onshore boom 

in production, reversing a long-term decline that had been expected to continue. Offshore, technological 

advancements in the oil and natural gas industry over the past several decades have greatly expanded the 

resources available for production. In addition, the offshore oil and gas industry has reduced deepwater 

project costs through greater equipment standardization and reduced rig dayrates. These cost reductions 

have allowed companies to sanction offshore projects even in this time of relatively low oil prices 

(Dunnahoe 2017). 

Additionally, regulatory changes, improvements in industry practices, and enhanced Bureau of Safety 

and Environmental Enforcement (BSEE) inspection capabilities have made OCS exploration and 

development safer and more environmentally sound. Companies can explore for, and develop, 

previously inaccessible resources. In addition, higher-quality geological and geophysical (G&G) data, 

achieved through state-of-the-art technology, acquisition methods, and processing, aid in identification 

of prospects and effective well placement, improving the probability of successful drilling operations. 

Advanced composite materials and materials engineering have improved OCS structures and moorings 

to better withstand the operating environment. These and other technologies developed for oil and gas 

operations have contributed to U.S. leadership in the worldwide energy industry. The importance of the 

United States as an offshore oil and gas technology leader was recognized in comments received in 

response to the RFI (see Appendix A). These technological advances support the country’s economic 

growth and help meet global energy needs. 

1.2.1.5 Employment and Public Revenues 

The domestic energy industry is an important component of the U.S. economy through its contribution to 

GDP, employment, and public revenues. Production of domestic oil and gas not only provides 

employment at higher-than-average wages to industry employees, but also provides work for many 

Americans in other industries that supply goods and services for exploration, development, production, 

and domestic transportation of oil and gas. The impact of the OCS oil and gas industry on GDP and 

employment is discussed in Chapter 8. Chapter 8 also describes the revenues available to local, state, 

and Federal governments. In general, OCS leasing and production provide the following public 

revenues: 

• billions of dollars a year in bonus bids, rentals, and royalties to the U.S. Treasury 

• funding for the Historic Preservation Fund 

• funding for the Land and Water Conservation Fund (LWCF) 

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• OCS Lands Act Section 8(g) and GOMESA revenue sharing payments to states5 

• indirect revenues via funding to state and local governments through worker and industry 

tax payments. 

1.3 PROGRAM DEVELOPMENT PROCESS 

The development of an OCS Oil and Gas Leasing Draft Proposed Program (Draft Proposed Program or 

DPP) is one of several Section 18 steps in the process of preparing a new 2019–2024 National OCS Oil 

and Gas Leasing Program (2019–2024 Program) that will follow or replace the current 

2017–2022 Program, which became effective on July 1, 2017, and expires on June 30, 2022, or when a 

new National OCS Program is approved. This DPP decision document constitutes the first of three 

proposals for an OCS lease sale schedule for the 2019–2024 timeframe. The three proposals include: 

(1) the DPP decision; (2) the Proposed Program decision; and (3) the Proposed Final Program (PFP) 

decision. 

The National OCS Program development process starts with the broadest consideration of areas 

available for leasing (all 26 OCS planning areas) and can be narrowed throughout the National OCS 

Program development and lease sale process. Once a defined area is proposed for leasing during the 

development of the National OCS Program, it becomes known as a program area. Program areas are the 

portions of the original OCS planning areas that remain in consideration for leasing during the National 

OCS Program development process. For example, the Cook Inlet Program Area in the 

2017–2022 Proposed Program included only the northern portion of the larger Cook Inlet Planning Area 

that was originally considered for leasing in the 2017–2022 DPP. In addition to the analyses and 

decision documents prepared pursuant to Section 18, once the initial program areas are identified in the 

DPP decision, BOEM has decided to prepare a Programmatic Environmental Impact Statement 

(Programmatic EIS) under the National Environmental Policy Act (NEPA) (42 U.S.C. 4321 et seq.) and 

its implementing regulations as a vehicle for conducting and disclosing the environmental analyses for 

the National OCS Program. BOEM’s decision to prepare the Programmatic EIS is discretionary because 

the U.S. Court of Appeals for the District of Columbia has ruled that the approval of a National OCS 

Program does not constitute an irreversible and irretrievable commitment of resources, and that, in the 

context of BOEM’s multiple-stage leasing program, the obligation to fully comply with NEPA does not 

mature until leases are issued (Center for Biological Diversity v. Department of the Interior, 385 563 

F.3d 466 [D.C. Cir. 2009]; Center for Sustainable Economy v. Jewell, 779 F.3d 588 [D.C. Cir. 2015]). 

The NEPA analysis will include an evaluation of the potential environmental and socioeconomic impacts 

associated with the proposed lease sale schedule, and how those impacts could vary depending on the 

areas or regions that are included in the National OCS Program (see Section 1.3.2). The NEPA process 

is introduced in the discussion on factor H in Section 2.2 in this document, with a more detailed 

description contained in the forthcoming Programmatic EIS. The Programmatic EIS will identify any 

sensitive areas that might warrant exclusion from leasing for oil and gas as well as mitigation measures 

5 Section 8(g) of the OCS Lands Act provides for the Federal Government to share with each coastal state hosting production 

27 percent of revenues earned from OCS leases within 3 nm seaward of the state’s submerged lands boundary. The shared 

revenues are referred to as “8(g) revenues.” In 2006, Congress passed the Gulf of Mexico Energy Security Act (GOMESA), 

which mandates that the states of Texas, Louisiana, Mississippi, and Alabama receive a portion of revenues from new oil and 

natural gas development in federal waters adjacent to the respective state. 

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for activities within leased areas that could have environmental impacts. The Programmatic EIS analysis 

will address whether mitigation measures are appropriate at the National OCS Program stage or should 

be deferred to the leasing or plan approval stages. The Programmatic EIS will address the cumulative 

effects of lease sales under the new National OCS Program, as well as those lease sale effects that could 

cross BOEM planning area boundaries, such as potential impacts on migratory animals. 

The key steps in preparing a new National OCS Program under Section 18 of the OCS Lands Act and the 

Programmatic EIS under Section 102(2)(C) of NEPA are shown in Figure 1-6, with a star identifying 

where BOEM is in the process of developing the 2019–2024 Program and associated NEPA analyses. 

Table 1-1 shows the NEPA assessments associated with the various stages of National OCS Program and 

lease sale development. 

The analysis contained in this DPP decision document examines and compares all 26 of the OCS 

planning areas in accordance with the Section 18 factors for consideration and balancing. However, only 

those areas and Program Options that the Secretary decides to include in his DPP decision will be 

analyzed in the Proposed Program decision document and the Draft Programmatic EIS. Subsequently, 

the program areas that the Secretary decides to include in the Proposed Program decision, and any 

potential subsets thereof, will be analyzed in the PFP decision document and in the Final Programmatic 

EIS. 

BOEM informs federally recognized tribal governments that a National OCS Program is being prepared, 

of the steps in the development process, and where to find additional information on meetings and other 

opportunities to provide comments. Recognizing the unique government-to-government relationship 

between the United States and Indian tribes, BOEM also invites requests for government-to-government 

consultation. This consultation can occur at the National OCS Program stage as well as during the 

subsequent stages of the process (e.g., lease sales, plan reviews). Consultation and coordination with 

other Federal agencies, and state and tribal governments, as required under specific environmental 

statutes, occur at subsequent stages of the process, as well. 

1.3.1 Request for Information and Comments 

In developing the 2019–2024 Program, BOEM considers, among other items, regional and national 

energy needs; leasing interests as expressed by possible oil and gas producers; applicable laws, goals, 

and policies mentioned in the comments of affected states; comments and concerns of local governments 

and tribes; public input; competing uses of the OCS; relative environmental sensitivity and marine 

productivity among OCS regions; and the equitable sharing of benefits and risks among OCS regions. 

On July 3, 2017, BOEM published in the Federal Register a Request for Information (RFI) regarding the 

preparation of a 2019–2024 Program, to commence in 2019, which would supersede the approved 

2017–2022 Program (82 FR 30886). BOEM also sent letters to all governors and the heads of interested 

Federal agencies requesting their input. Summaries of the public comments received on the RFI are 

included in Appendix A. 

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Figure 1-6: National OCS Oil and Gas Leasing Program and Development Process 

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Table 1-1: NEPA Assessments Typically Conducted for the OCS Oil and Gas Leasing Program 

Program 

Level Program Stage NEPA Analysis Geographic Scope Focus and Scope 

Planning National OCS 

Program 

Programmatic EIS 

(NEPA is 

discretionary at this 

stage.) 

Continental 

Identification of program areas, 

number, and schedule of lease 

sales for the National OCS 

Program, and identification of 

National OCS Program-level 

environmental impacts and 

mitigation measures. 

Lease sale Lease sale NEPA Review 

(EIS, EA, or DNA) Program area 

Identification of potential 

environmental impacts and 

mitigation measures (EIS or 

EA), or determination that 

these are adequately covered in 

a previously prepared NEPA 

document (DNA) 

Exploration CER, EA, or EIS Lease block(s) Selection and application of 

mitigation measures 

Project 

Production CER, EA, or EIS Portion of lease 

block 

Decommissioning CER, EA, or EIS 

Specific facility 

within a lease 

block 

Note: The level of NEPA analysis at the project level is determined by the complexity of the project, risk factors associated 

with the project, project location relative to existing oil and gas activities in the area, the technologies proposed for use, and 

other factors. 

Key: CER=categorical exclusion review; DNA= Determination of NEPA Adequacy; EA=environmental assessment; 

EIS=environmental impact statement. 

1.3.2 Draft Proposed Program and Notice of Intent to Prepare a 

Programmatic Environmental Impact Statement 

After considering all of the analyses associated with the Section 18 factors and principles (see Chapter 2), 

the Secretary selects Program Options as part of the DPP decision (as discussed in Part I). This decision 

represents the initial proposal for the 2019–2024 Program. BOEM announces the availability of the DPP 

in the Federal Register, as well as the Notice of Intent (NOI) to discretionally prepare a Programmatic 

EIS, which signals the initiation of the NEPA process. Following the publication of the DPP and NOI, a 

60-

day comment period is initiated in which BOEM solicits comments on the DPP and requests scoping 

comments relevant to the development of the Programmatic EIS. BOEM also transmits the DPP decision 

document to all 50 governors and relevant Federal agencies, and begins development of the Draft 

Programmatic EIS. 

1.3.3 Proposed Program and Draft Programmatic EIS 

Preparation of the 2019–2024 Proposed Program will be based on additional analyses of required 

Section 18 factors (see Chapter 2) and comments received by BOEM on the DPP and NOI. As such, the 

2019–2024 Proposed Program decision is the second version of the Secretary’s proposal for this National 

OCS Program. OCS areas identified for potential leasing in the DPP will be analyzed in the Proposed 

Program and Draft Programmatic EIS. 

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BOEM will announce the publication of the Proposed Program and Draft Programmatic EIS and 

associated request for comments in the Federal Register. The Proposed Program will be submitted to 

governors and relevant Federal agencies. In that Federal Register notice, BOEM will also request 

feedback on the Proposed Program and Draft Programmatic EIS from other interested and affected parties 

during a 90-day comment period. As provided in Section 18 of the OCS Lands Act, BOEM will provide 

written responses to governors and the Attorney General on their comments on the Proposed Program in 

conjunction with transmittal of the PFP and Final Programmatic EIS. 

1.3.4 Proposed Final Program and Final Programmatic EIS 

At the last phase of the National OCS Program analysis, BOEM will prepare a PFP based on additional 

analyses of Section 18 factors and comments BOEM received on the Proposed Program and Draft 

Programmatic EIS. The PFP is the third and last version of the Secretary’s proposal. Additionally, a 

Final Programmatic EIS will be developed and released in conjunction with the PFP. OCS areas 

identified for potential leasing in the Proposed Program will be analyzed in the PFP and Final 

Programmatic EIS. BOEM will announce publication of the PFP in the Federal Register and will submit 

it to the President and Congress, along with the Final Programmatic EIS. Copies of all incoming 

comments received on the Proposed Program and responses to comments on the Proposed Program 

received from state and local governments and Federal agencies will also be submitted to the President 

and Congress. In accordance with Section 18(c)(2), the Secretary will not approve the PFP until at least 

60 days after sending it to the President and Congress. 

1.3.5 Program Approval and Record of Decision 

Sixty days after the PFP is submitted to the President and Congress, the Secretary may approve the 

2019–2024 Program. At the time of approval, the Secretary’s decision is described in the Record of 

Decision (ROD) that is made publicly available. The ROD is the final step in the Programmatic EIS 

process and, in general, identifies the selected alternative, presents the basis for the decision, and provides 

information on the methods to avoid, minimize, or otherwise mitigate environmental impacts. The ROD 

could adopt any programmatic mitigation measures, geographic exclusions or other restrictions on leasing 

activities that the Secretary considers necessary for environmental protection and that are sufficiently 

identifiable at the Programmatic stage. 

1.4 LEASE SALE PROCESS 

Approval of a National OCS Program does not constitute approval of the lease sales scheduled in that 

program. Each potential lease sale scheduled in the 2019–2024 Program will be subject to separate 

established pre-lease decision processes, including environmental review and analysis. Interested and 

affected parties have multiple opportunities to participate and comment prior to any decision to hold a 

specific lease sale (see Figure 1-6). The leasing process has traditionally taken about two years to 

complete, and contains multiple steps and decision points along the way. Generally, the process begins 

with a Call for Information and Nominations (Call), where BOEM solicits public input on areas of 

interest or concern, and specifically solicits industry interest on areas that should be considered for 

leasing. After the Call, BOEM completes and announces its Area Identification (Area ID), which 

determines the discrete area that will be considered for leasing and for further environmental analysis. 

BOEM then prepares and publishes a Proposed Notice of Sale (NOS), which announces the proposed 

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sale’s size, timing, and terms and conditions, including any mitigation measures necessary to protect the 

environment and reduce potential conflicts-of-use. After required consultations and environmental 

review are completed, BOEM publishes a Final NOS, which includes the date, time, and location of the 

bid opening, the OCS blocks being offered, and the terms and conditions of the lease sale. The full 

process is described below in more detail. 

1. Call for Information and Nominations (30 CFR 556.301)—In the first step of the lease sale 

process, BOEM issues a Call in the Federal Register on an area that was proposed for leasing in 

the National OCS Program. Potential bidders are invited to submit nominations or indications of 

interest in specific OCS blocks within the area included in the Call. The Call also solicits 

comments about geological conditions; archaeological sites; multiple uses of the area; 

sociological, biological, and other environmental information; and asks the public for information 

on areas of special concern that should be analyzed. 

2. Review under NEPA—Each individual lease sale requires a NEPA review. This could include 

preparation of a programmatic EIS covering the sales identified in an approved National OCS 

Program for a given region or Program Area. Subsequent lease sales could then be covered by an 

EA, Determination of NEPA Adequacy (DNA), or, if new information or circumstances warrant, 

a Supplemental EIS. 

3. Area Identification (30 CFR 556.302)—Area ID identifies the area proposed for leasing and 

further environmental analysis. Based on information gathered from responses to the Call and the 

NOI, BOEM will identify the Proposed Action to be analyzed in the NEPA document. BOEM 

publishes the Area ID decision in the Federal Register. 

4. Government-to-Government Consultations—BOEM consults with federally recognized tribes. 

In Alaska, BOEM additionally consults with Alaska Native Claims Settlement Act Corporations. 

These consultations are conducted throughout the OCS oil and gas lease sale process. 

5. Environmental Consultations—Consultations under various environmental statutes occur, such 

as the Endangered Species Act (ESA) of 1973 (16 U.S.C. § 1531 et seq.) and the 

Magnuson-Stevens Fishery Conservation and Management Act (16 U.S.C. § 1801 et seq.), with 

Federal agencies such as the U.S. Fish and Wildlife Service (USFWS) and National Marine 

Fisheries Service (NMFS). BOEM also consults with State Historic Preservation officers under 

Section 106 of the National Historic Preservation Act (54 U.S.C. § 306108). 

6. Proposed NOS (30 CFR 556.304)—The Proposed NOS describes the timing, size, and location 

of a proposed oil and gas lease sale. It also provides potential bidders with information on 

proposed lease terms and conditions, including any proposed environmental mitigations. BOEM 

publishes a Notice of Availability of the Proposed NOS in the Federal Register. 

7. Coordination with Governors of Affected States (30 CFR 556.304-305)—Section 19 of the 

OCS Lands Act (43 U.S.C. § 1345) requires BOEM to solicit input on the size, timing, and 

location of lease sales from governors of affected states. BOEM sends the Proposed NOS to 

governors of affected states requesting their recommendations on the proposed lease sale’s size, 

timing and location. The governors have 60 days to submit their recommendations to BOEM. 

8. Consistency Determination (30 CFR 556.305(b))—All Federal activities, including OCS oil 

and gas lease sales, must be consistent to the maximum extent practicable with the enforceable 

policies of an affected state’s coastal zone management (CZM) program (see 

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16 U.S.C. § 1456(c)(1) and (2)). BOEM provides coastal states with a Consistency 

Determination on whether the proposed lease sale is consistent, to the maximum extent 

practicable, with the enforceable policies of federally approved state Coastal Management Plans 

(CMPs). Currently, the State of Alaska does not have a federally approved CMP. 

9. Issuance of a Record of Decision (EIS-level), Finding of No New Significant Impact 

(EAlevel) or Determination of NEPA Adequacy—The NEPA review for each individual lease 

sale must be completed before the sale can occur. Depending on the NEPA review undertaken 

for a lease sale, this could be through the issuance of a ROD, a Finding of No New Significant 

Impact, or a DNA. 

10. Final NOS (30 CFR 556.308(a))—BOEM will publish a Final NOS at least 30 days before a 

lease sale is held. The Final NOS includes information on (1) how to submit bids; (2) the date, 

time, and location of the bid opening and reading; (3) the OCS blocks being offered; and 

(4) terms and conditions of the lease sale, including required environmental mitigations. 

11. Holding the Lease Sale (30 CFR 556.516)—BOEM opens the sealed bids at the place, date, and 

hour specified in the Final NOS for the sole purpose of publicly announcing and recording the 

bids. BOEM does not accept or reject any bids at that time. High bids are subject to further 

evaluation regarding the receipt of fair market value (FMV) for the United States and adequate 

competition before a lease can be issued. 

12. Lease Issuance (30 CFR 556.520-522)—BOEM will issue a lease following completion of the 

FMV analysis and review by the Department of Justice, in consultation with the Federal Trade 

Commission. The Department of Justice, in consultation with the Federal Trade Commission, has 

30 days to conduct antitrust review of the lease sale, but could agree to a shorter review period. 

1.5 EXPLORATION AND DEVELOPMENT PROCESS 

After BOEM issues a lease, a lessee typically begins a process of exploration for oil and gas 

accumulations. An Exploration Plan is submitted to BOEM so that BOEM can perform environmental 

review and possibly approve the plan (see Figure 1-6). In some cases, these potential resources could 

already be identified through analysis of existing data and information. In other cases, a lessee could 

need to utilize information collected through a much broader exploration program to identify potential 

resources in areas where exploration data coverage is less dense or non-existent. The general process for 

oil and gas exploration on a lease typically begins by conducting geophysical seismic surveys early in an 

exploration cycle to obtain information about subsurface geologic formations and potential oil and gas 

traps. Such activity on a lease is conducted pursuant to the lease and/or plan requirements and does not 

require a separate permit, as is the case for pre-lease survey activity. Seismic survey techniques and 

technologies are continuously becoming more sophisticated. Generally, areas with mature oil and gas 

development, such as in the GOM, have more recent, and therefore more sophisticated seismic data 

available (e.g., three-dimensional [3-D] seismic surveys), while older, less sophisticated seismic data 

(e.g., two-dimensional [2-D] seismic surveys) is often all that is available to delineate frontier areas, like 

in the Atlantic Region. As activity increases in frontier areas, new seismic data will be collected and 

more detailed information will become available. 

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High-resolution geophysical surveys on a lease are performed prior to exploration plan submittal to 

identify natural and man-made hazards, areas of potential benthic habitat such as hard bottom habitat and 

coral reefs, and significant cultural resources such as historic shipwrecks or inundated occupation sites on 

or below the seabed. The next phase of exploration involves drilling an exploration well that targets the 

interpreted oil or gas trap in the subsurface to determine if an oil and/or gas resource exists. If oil or gas 

is discovered in quantities appearing to be economically favorable, one or more follow-up delineation 

wells could be drilled to help define the amount of resource or the extent of the reservoir. 

Delineation and production wells are sometimes collectively termed development wells. If a lessee 

wishes to drill a development well, a Development and Production Plan must be submitted to BOEM so 

that BOEM can perform environmental review and possibly approve the plan (see Figure 1-6). Assuming 

that hydrocarbon resources are discovered and successfully delineated, a production facility could be 

installed at the site. The number of wells per facility varies according to the type of production facility 

used, the prospect site, and the drilling and production strategy deployed. Oil and gas are brought to 

market via a system of pipelines and processing facilities or through production into a floating system. 

Exploration plans and development and production plans outside the GOM, and deepwater plans in the 

GOM, are subject to focused, site-specific environmental analyses under NEPA and other environmental 

statutes as well as the requirement for an operator to certify consistency of the proposed activities with the 

state’s CZM program, as appropriate. 

For more information about the exploration and development process, see BOEM’s web pages: 

https://www.boem.gov/Status-of-Gulf-of-Mexico-Plans/ and https://www.boem.gov/akplans. For more 

information about BOEM’s oil and gas resource evaluation program, see BOEM’s web page: 

https://www.boem.gov/Resource-Evaluation-Program/. 

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Chapter 2 Section 18 Factors for Consideration and Balancing 

2.1 BOEM’S APPROACH TO ANALYZING PLANNING AREAS 

Section 18(a) of the OCS Lands Act contains four subsections which set forth specific principles and 

factors that guide National OCS Program formulation and which, together, provide the foundation for 

BOEM’s analysis that is used in the development of Program Options for a schedule of proposed lease 

sales. The Secretary may select from these Program Options “indicating, as precisely as possible, the 

size, timing, and location of leasing activity which [the Secretary] determines will best meet national 

energy needs for the five-year period following its approval...” (43 U.S.C. §1344(a)). A brief overview 

of those Section 18 requirements is presented in this chapter, which also includes judicial guidance 

provided in court decisions on prior National OCS Programs (see Section 2.7, Judicial Guidance). This 

DPP decision document contains analyses of all 26 OCS planning areas pursuant to the principles and 

factors articulated by Section 18 of the OCS Lands Act, including, but not limited to, the eight factors 

listed in Section 18(a)(2) of the OCS Lands Act (see Section 2.2, Section 18(a): Factors for Determining 

Size, Timing, and Location of Leasing). The Secretary’s proposal, as presented in Part I, identifies areas 

for further leasing consideration, consisting of some of the 26 OCS planning areas. Once the Secretary 

proposes areas for inclusion in the National OCS Program, those areas become “program areas.” See 

further discussion of planning and program areas in Section 4.1. The Program Options presented in Part I 

will be analyzed in the Proposed Program and Draft Programmatic EIS. 

The analyses underlying the 2019–2024 Program use the best available information. Previous studies and 

analyses are augmented by the latest documents, reports, and studies available, along with pertinent 

information provided in comments on the RFI. Additionally, BOEM reviews and reinterprets existing oil 

and gas resource data as necessary. The DPP lease sale schedule provides the initial Proposed Action to 

be analyzed in the Proposed Program and Draft Programmatic EIS. The Draft Programmatic EIS is 

published in conjunction with the Proposed Program decision document. The Proposed Program lease 

sale schedule provides the refined Proposed Action analyzed in the PFP and Final Programmatic EIS. 

The Final Programmatic EIS is published in conjunction with the PFP decision document. 

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2.2 SECTION 18(A): FACTORS FOR DETERMINING SIZE, TIMING, AND 

LOCATION OF LEASING 

As stated above, Section 18(a) of the OCS Lands Act states that a five-year leasing program must be 

prepared and maintained by the Secretary consistent with principles set forth in the section. Section 

18(a)(2) lists eight factors that the Secretary must consider when determining the size, timing, and 

location of oil and gas activities among the different areas of the OCS. While some of these factors lend 

themselves to quantification for facilitating the comparison among planning areas, others do not and need 

to be considered qualitatively. Each of the eight factors provided in Section 18(a)(2)(A) through (H) is 

listed below: 

A) Geographical, Geological, and Ecological Characteristics 

The main sources of information on geographical, geological, and ecological characteristics of the OCS 

planning areas considered in preparing this DPP analysis are the 2017–2022 Programmatic EIS, other 

recently completed Federal agency NEPA documents prepared for leasing and operational activities, 

BOEM oil and gas resource assessments and associated regional geologic and reserves reports, the 

1994 National Research Council report concerning information for Alaska OCS decisions (NRC 1994), 

scientific study results (as reported in BOEM’s Environmental Studies Program Information System 

[ESPIS]), published and unpublished but vetted scientific literature, expert knowledge, and information 

submitted or cited by commenters. Such information can be found in various places in this decision 

document (e.g., geological characteristics in Chapter 5 and geographical and ecological characteristics in 

Chapter 7). Additional information on the ecological characteristics will be included in the Draft 

Programmatic EIS. 

B) Equitable Sharing of Developmental Benefits and Environmental Risks 

Chapter 8 analyzes the equitable sharing of developmental benefits and environmental risks associated 

with oil and gas leasing. The chapter provides a discussion of the developmental benefits that accrue in 

regions near existing and potential OCS oil and gas production and the benefits that are distributed widely 

throughout the United States. The onshore areas adjacent to the regions possessing substantial oil and gas 

resources tend to both receive most of the benefits from, and be subject to the associated environmental 

risks of, developing those resources. Developmental benefits analyzed include increased wages, 

additional jobs, increased tax collection, revenue sharing where applicable, and proximity of supply to 

consumers of energy. 

Environmental risks (impacts) include the potential for activities stemming from the DPP decision to 

adversely affect (1) the quality of the human environment (e.g., water quality, air quality, accidental or 

catastrophic oil spill events); (2) species and habitats, including those that are commercially, culturally, or 

recreationally valuable (e.g., commercial fisheries, coastal tourism, subsistence harvest); (3) species and 

habitats that are protected by Federal environmental laws and regulations; (4) cultural and archaeological 

resources; (5) access to subsistence resources; or (6) overall marine productivity that could affect or 

diminish ecosystem services. By discussing the impacts that affect both regional and national interests, 

Chapter 8 provides the Secretary with information on the sharing of developmental benefits and 

environmental risks. In addition, the Draft Programmatic EIS will analyze the potential impacts that 

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could occur from leasing activities under the National OCS Program. The impact analysis will further 

inform the discussion of environmental risks. 

C) Location with Respect to Regional and National Energy Markets and Needs 

The analyses in Chapter 6 focus on recent developments in energy markets, including recent low oil and 

gas prices.6 The analyses include the U.S. Department of Energy’s projections of national and regional 

production and consumption according to the EIA’s Annual Energy Outlook (AEO) 2017 (EIA 2017); the 

potential contribution of OCS oil and gas production in meeting national energy needs; regional energy 

markets and the location of OCS planning areas; and alternatives to OCS production. 

D) Location with Respect to Other Uses of the Sea and Seabed 

Section 6.5 discusses competing uses of the OCS. This section includes information received from 

Federal, state, and local government agencies; tribal governments, environmental organizations; and 

regional fishery management bodies (see Appendix A); as well as information provided by BOEM’s 

Marine Minerals and Renewable Energy programs. 

Other uses of the sea and seabed will be covered in the Draft Programmatic EIS as well. The discussion 

of past, present, and reasonably foreseeable future actions in the Draft Programmatic EIS will include a 

characterization of OCS activities, other than 2019–2024 Program activities, that could affect 

environmental resources on or adjacent to the OCS. 

E) Laws, Goals, and Policies of Affected States Identified by Governors 

Section 9.2 includes summaries of the relevant laws, goals, and policies—including federally approved 

CZM programs and policies—that state governments identified when responding to BOEM’s request for 

comments. As required by Section 18(c)(1), BOEM sent letters to the governors of all 50 states 

requesting their suggestions and asking them to identify any relevant state laws, goals, and policies for the 

Secretary’s consideration. Appendix A summarizes the comments received on the RFI, including those 

from governors and state government agencies. 

F) Interest of Potential Oil and Gas Producers 

Section 9.1 describes industry interest as indicated in response to the RFI. Appendix A summarizes the 

comments received, including those from oil and natural gas companies and associations in the 

exploration and production sector of the energy industry. 

G) Relative Environmental Sensitivity and Marine Productivity 

Chapter 7 contains an analysis of the environmental sensitivity and marine productivity for the planning 

areas. In Chapter 7, as in previous National OCS Programs, BOEM defines the term “sensitivity” as 

sensitivity to potential impacts from oil and gas exploration and development as measured by indicators 

of vulnerability to impact. Additional information on the plants, animals, habitats, and human activities 

that could affect the sensitivity of an area will be provided in the Draft Programmatic EIS as well. 

6 Section 1.2 also addresses energy needs but with respect to the overriding purpose of the National OCS Program “to best meet 

national energy needs ....” As noted above, the focus of Chapter 6 is on providing information to allow the Secretary to meet the 

requirements of Section 18(a)(2)(C). 

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An estimate of OCS marine productivity is also included in this analysis. Productivity is defined as the 

rate of biomass production per unit of time. In the marine environment, primary production conducted 

via photosynthesis determines the total amount of biomass available to higher trophic levels. However, 

the relationship between primary and secondary or higher level production is not straightforward or 

uniform across marine ecosystems (Pomeroy 1991). Higher level productivity is difficult to estimate, 

especially across geographically large and ecologically diverse areas, such as the OCS 

(Balcom et al. 2011). Furthermore, measurements for the BOEM ecoregion areas were produced using 

satellite-based measurements of chlorophyll-a, available light, and photosynthetic efficiency 

(Balcom et al. 2011). These rates are on an areal basis so direct comparisons among planning areas of 

different sizes can be made. 

H) Environmental and Predictive Information 

Chapter 7 provides a summary of environmental and cultural resource information for each OCS region, 

which includes the ecological considerations and portions of the geographic and geological considerations 

that are relevant to determining when and where leasing should occur. Chapter 7 includes a discussion of 

the most relevant environmental issues and builds on the environmental setting to discuss the predictive 

information relevant to potential environmental impacts. It provides a broad overview of the types of 

relationships between resources and impact-producing factors (IPFs) that could result in impacts on those 

resources. The nature and severity of these impacts will be analyzed in the Programmatic EIS for the 

2019–2024 Program. 

2.3 SECTION 18(A)(3): BALANCING THE POTENTIAL FOR ENVIRONMENTAL 

DAMAGE, DISCOVERY OF OIL AND GAS, AND ADVERSE IMPACT ON THE 

COASTAL ZONE 

Another of the Section 18(a) guiding principles is found in Section 18(a)(3), which requires the Secretary, 

when making decisions on the size, timing, and location of OCS leasing, to strike a balance among the 

potential for environmental damage, the discovery of oil and gas, and adverse impacts on the coastal 

zone. The Secretary’s balancing effort must be informed by his analysis of the Section 18(a)(2) factors. 

Part III of this DPP decision document presents a comparative analysis of all 26 planning areas. 

For the DPP, an element of the comparative analysis is an estimation of societal net benefits for each 

planning area, derived by calculating the value of undiscovered economically recoverable oil and natural 

gas resources (UERR) minus the cost to industry and the environmental and social costs of developing 

those resources. BOEM refers to the results of this analysis as the net social value (NSV) (see 

Section 5.3).7 See also the descriptions of the various types of “value” in Section 2.6, 

Section 18(a)(1): Economic, Social, and Environmental Values. 

The environmental sensitivity index compares and ranks the sensitivity of the different BOEM ecoregions 

based upon quantified information relating to environmental sensitivity and marine productivity (see 

Chapter 7). Each planning area within an ecoregion is assigned a sensitivity score based upon the 

ecoregion as a whole. The comparative analysis uses these scores to rank the environmental sensitivity of 

7 As explained below, for later programmatic analyses, the NSV and additional estimates will reflect production and related 

activities anticipated to result specifically from the National OCS Program decision. 

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the planning areas based on their relative vulnerability and sensitivity to oil and gas development. The 

marine primary productivity of each planning area was also calculated. Both the environmental 

sensitivity and productivity are then related to the interest of potential oil and natural gas producers (see 

Section 9.1). Other Section 18(a)(2) factors, including geographical, geological, and ecological 

characteristics and laws, goals, and policies of affected states, do not lend themselves to quantification 

and are, therefore, treated qualitatively. The comparative analysis also examines additional qualitative 

information pertaining to the findings and purposes of the OCS Lands Act, the comments and 

recommendations of interested and affected parties, and other information relevant to striking a proper 

balance under Section 18(a)(3). 

The OCS Lands Act does not specify how the factors in Section 18(a)(2) should be weighed to achieve 

the balancing required by Section 18(a)(3), leaving it to the Secretary’s discretion to reach a reasonable 

determination under the existing circumstances. 

2.4 SECTION 18(A)(4): ASSURANCE OF FAIR MARKET VALUE 

Section 18(a)(4) of the OCS Lands Act requires receipt of FMV from OCS oil and gas leases. BOEM’s 

two-phase, post-sale bid evaluation process used since 1983 assures the FMV requirement is met for the 

issuance of individual leases. Historically, this process has considered geologic and auction market 

factors in phase one and economic factors in phase two. In addition to the assurance of FMV in the 

National OCS Program development and implementation process, BOEM continues to assess market and 

resource conditions as each lease sale approaches, and designs the lease sale fiscal terms to achieve FMV. 

Additional information on, and analysis of, FMV is contained in Chapter 10, which also considers the 

uncertainties surrounding OCS oil and gas leasing, and how these uncertainties can impact the value of 

OCS acreage. 

2.5 SECTION 18(A): ENERGY NEEDS 

As stated in Section 18(a) of the OCS Lands Act, the purpose of the National OCS Program is to help 

meet the future energy needs of the United States. Section 1.2, Energy Needs, presents an analysis of 

anticipated energy needs from the perspective of meeting the goals of the OCS Lands Act, which 

recognizes the importance of oil and gas exploration, development, and production, not only to provide 

fuel to consumers of all types, but also to support job creation; improve the GDP, the national balance of 

trade, and national energy security; and as an integral component to national economic and energy 

policies in general.8 

2.6 SECTION 18(A)(1): ECONOMIC, SOCIAL, AND ENVIRONMENTAL VALUES 

Section 18(a)(1) of the OCS Lands Act requires that the Secretary manage the OCS “in a manner which 

considers economic, social, and environmental values of the renewable and non-renewable resources 

contained in the outer Continental Shelf....” The DPP analyses presented in Part III of this document are 

conducted to ensure that economic, social, and environmental values associated with exploration, 

8 Chapter 6 addresses similar energy subjects but instead of focusing on broad themes, Chapter 6 focuses on information the 

Secretary must consider pursuant to Section 18(a)(2)(C), discussed in Section 2.2, Section 18(a): Factors Determining Size, 

Timing, and Location of Leasing. 

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development, and production of OCS resources are incorporated as important aspects of the National 

OCS Program’s development. The OCS Lands Act also requires the Secretary to consider potential 

impacts that oil and gas activities could have on other resource values of the OCS and on the marine, 

coastal, and human environments. The purpose of the analyses performed for the DPP is to assist the 

Secretary with meeting these requirements (including the balancing requirement described in Section 2.3, 

Section 18(a)(3): Balancing the Potential for Environmental Damage, Discovery of Oil and Gas, and 

Adverse Impact on the Coastal Zone), in consideration with the other analyses. 

Chapter 7 presents the environmental setting for each of the OCS regions (Alaska, Pacific, GOM, and 

Atlantic), which includes relevant environmental information on habitats, species types and distribution, 

and federally protected species. Appendix A contains summaries of comments received in response to the 

RFI, including issues or concerns that were identified by commenters. The environmental considerations 

section also includes information from previous National OCS Program decision documents and 

references to available environmental resource information. Finally, a brief discussion of predictive 

information is provided to identify the potential relevant impacts and the resource areas that could be 

affected. 

2.6.1 Economic Value 

Economic value will be realized from decades of oil and natural gas activity and production that result 

from leases awarded during the implementation of the National OCS Program. Several metrics are used 

to calculate economic value, such as net economic value (NEV) of the extracted oil and natural gas 

resources; employment, wages, and income from oil and natural gas activity;9 and government receipts of 

cash bonuses, rentals, royalties, and taxes. Economic values are discussed primarily in NSV 

(Section 5.3), Equitable Sharing Considerations (Chapter 8), and Assurance of Fair Market Value 

(Chapter 10). 

2.6.2 Social Value 

Social value is realized when OCS resources are combined with inputs or processes to generate 

improvements in the lives of people or benefits to society. When OCS resources are used to maximize 

social value, the National OCS Program is being efficiently managed. Social value can be negatively 

impacted (a social welfare loss) when OCS resources are not developed in the interest of conservation10 

or when oil and gas activities result in adverse consequences to society, such as a highly damaging event 

like a large oil spill. At the same time, energy substitutes for forgone OCS oil and gas production can 

also cause social welfare losses, resulting from such things as spills of imported oil or air pollution from 

increased onshore production. Social values include cultural and community values but also broad 

considerations of a wide array of factors, many of which could also be considered economic or 

environmental effects. Components of social value are reflected in all of the substantive requirements 

analyses prepared in support of this DPP, whether accounted for in NSV or described qualitatively. 

Social values are especially relevant in Part III, Analysis and Results. 

9 Consistent with standard practices in cost-benefit analysis, the analysis in Part III, treats employment, wages, and income as 

costs necessary to obtain the oil and natural gas that provide economic value. However, in general, these results of OCS 

development are widely viewed as benefits to society, and they are treated as such in Chapter 8. 10 In this context, conservation refers to the responsible development of oil and gas resources by preventing waste and 

maximizing recovery of economically producible reservoirs (MMS 2007). 

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2.6.3 Environmental Value 

Environmental value is the worth society places on the intrinsic natural capital in the OCS’s renewable 

and non-renewable resources. Natural capital provides goods and services from nature, including marine 

productivity, quality of aesthetic resources, human-ecological connectivity, and air and water quality. 

The analyses presented in Chapter 7 discuss environmental sensitivity and marine productivity, and the 

important effect of relevant environmental impacts on environmental value. Section 18(a)(2)(G) calls for 

the consideration of the relative environmental sensitivity and marine productivity of the OCS. BOEM 

sponsored the development of a new method for performing the corresponding assessment for the 

2017–2022 Program, the results of which were first presented in the 2017‒2022 DPP decision document. 

See Section 2.2 (G) and Chapter 7 in this document for methodological explanations. Feedback from 

internal and external reviews of this new approach was incorporated into the analysis for the 

2017–2022 PFP document. 

2.7 JUDICIAL GUIDANCE 

The 2019–2024 Program will be the tenth National OCS Program prepared by the Department. Pursuant 

to Section 23(c)(1) of the OCS Lands Act, all challenges to the National OCS Program are heard in the 

U.S. Court of Appeals for the D.C. Circuit. The 1980–1985, 1982–1987, 1987–1992, 2007–2012, and 

2012–2017 Programs prepared and approved under Section 18 were challenged in court. No lawsuits 

were filed with respect to the approved 1992–1997, 1997–2002, 2002–2007, or 2017–2022 Programs. 

The 2019–2024 Program is being prepared in accordance with guidance provided in those court decisions 

addressing past National OCS Programs. A brief description of the findings of each decision and how 

they have guided preparation of the National OCS Programs over time follows. 

• California v. Watt, 688 F.2d 1290 (D.C. Cir. 1981) (California I)—In this case, the State of 

California challenged the 1980–1985 Program. This National OCS Program was the first that 

followed the passage of the OCS Lands Act Amendments of 1978, which added the Section 18 

requirement for a leasing program. The court stated that the Secretary must consider all eight 

factors and not defer consideration of required factors to later stages because more information 

might be available. It accepted the use of a cost-benefit-type analysis and recognized that certain 

analyses could be qualitative. The court found that the three balancing factors in Section 18(a)(3) 

were not inherently equal and the Secretary had discretion in weighting them, as long as the 

decision was not arbitrary. The case was remanded to consider those of the eight factors not 

previously considered, better quantify environmental costs, and present a coherent explanation on 

how NEV is determined and the value of deferring leasing. However, because a new National 

OCS Program for 1982–1987 was already in preparation, the 1980–1985 Program was not 

revised. 

• California v. Watt, 712 F.2d 584 (D.C. Cir. 1983) (California II)—In this case, the court held that 

the 1982–1987 Program met the requirements found lacking in the 1980–1985 Program. The 

court upheld the methodology and assumptions used for the NSV analysis. The court reiterated 

the “pyramidic” nature of the entire leasing process and upheld the first use of area-wide leasing 

because exact tracts (blocks) do not need to be identified at the National OCS Program stage. It 

found that receipt of FMV does not mean “maximization of revenues” and validated the post-sale 

bid evaluation methodology. The court also stated that once the determination has been made to 

not consider an area for leasing, that area does not need to be analyzed further. 

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• Natural Resources Defense Council, et al. v. Hodel, 865 F.2d 288 (D.C. Cir. 1988)—In this case, 

the court remanded the 1987–1992 Program for better NEPA coverage of cumulative impacts of 

simultaneous development in different planning areas. The court validated the use of 

administratively established planning areas as the basis for comparing “oil- and gas-bearing 

physiographic regions,” a term used, but not defined, in the OCS Lands Act. As in the previous 

cases, the court upheld the cost-benefit methodology and assumptions used. The court stated that 

while the Secretary was required to receive and consider nominations for exclusion of areas, there 

was no requirement to exclude nominated areas. Should a decision be made to exclude an area, 

the court agreed with the Secretary that such exclusion decisions must be reasoned and the basis 

for making them identified, but there did not need to be a “formula” for such decisions. The court 

cited California I (at 1321–22) to explain that the Secretary’s duty as to the exclusion decisions is 

“simply to identify his legal or factual basis and to exp1ain why he acted as he did.” Also once 

an area is excluded from availability for leasing, “[t]he Secretary need not perform a Section 18 

analysis” on that area (California II at 608). 

• Center for Biological Diversity, et al. v. Department of the Interior, 563 F.3d 466 

(D.C. Cir. 2009)—In this case, the court remanded the 2007–2012 Program for failure to consider 

the relative environmental sensitivity and marine productivity of “different areas of the outer 

Continental Shelf,” not just the shoreline, and required the Secretary to rebalance under 

Section 18(a)(3) using the revised analysis along with the other seven factors. The court also 

found that the OCS Lands Act does not require consideration of the impact of consuming OCS oil 

and gas and denied the NEPA claims presented in this case, holding the claims not ripe because 

an agency’s NEPA obligations mature only once it reaches a critical stage of a decision, which 

will result in irreversible and irretrievable commitments of resources that will affect the 

environment. The court reasoned that in the case of the National OCS Program, the point of 

irreversible and irretrievable commitment of resources and the concomitant obligation to fully 

comply with NEPA does not occur until leases are issued. 

• Center for Sustainable Economy(CSE) v. Jewell, 779 F.3d 588 (D.C. Cir. 2015)—The court 

found that CSE’s NEPA challenges were unripe because the Department makes no irreversible 

commitment of resources at the National OCS Program stage, and upheld the Department’s 

chosen methods of cost-benefit analysis as reasonable and consistent with the statute. 

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Chapter 3 Outreach and Coordination 

BOEM’s outreach and coordination with other Federal agencies; state, local, and tribal governments; nongovernmental organizations; and the public is a crucial part of the program development process. 

BOEM’s outreach and public involvement efforts strive to encourage open and continued communication 

between and among these groups to share ideas and concerns, and to ensure that accurate and timely 

information is exchanged. 

Section 18 of the OCS Lands Act specifies a multi-step process of public involvement and analysis that 

must be completed before the Secretary may approve a new National OCS Program. This process 

requires the Secretary to consider, among other factors, comments and concerns of local governments and 

tribes, public input, and competing uses of the OCS. Additionally, the OCS Lands Act requires the 

consideration of the laws, goals, and policies of affected states that have been specifically identified in 

comments received from governors, and the interest of potential oil and gas producers in the development 

of oil and gas resources as indicated by exploration or nomination (i.e., industry interest). Industry 

interest is discussed in Section 9.1 and laws, goals, and policies of affected states that were identified by 

governors’ comments are discussed in Section 9.2. 

The National OCS Program development process provides multiple opportunities for stakeholders and the 

general public to provide comments, with three comment opportunities under the OCS Lands Act process 

and two under the NEPA process. 

3.1 REQUEST FOR INFORMATION AND COMMENTS 

On July 3, 2017, BOEM published in the Federal Register an RFI, which is the first step in the 

preparation of a new National OCS Program (82 FR 30886). BOEM also sent letters to all governors and 

potentially interested Federal agencies requesting their input. BOEM received a total of approximately 

816,000 comments in response to the RFI (see Appendix A for a summary of comments received on the 

RFI). See Figure 3-1 for a breakdown of comment letters received by commenter category. 

The publication of the 2019–2024 DPP initiates a 60-day public comment period. A scoping comment 

period for the Programmatic EIS will occur concurrently with the DPP public comment period. 

The publication of the 2019–2024 Proposed Program and Draft Programmatic EIS will initiate a 90-day 

public comment period. 

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Figure 3-1: Request for Information Comment Letters by Commenter Category 

General Public 

3.2 PUBLIC MEETINGS FOR THE NATIONAL OCS PROGRAM AND 

PROGRAMMATIC EIS 

In addition to the procedural requirements under Section 18, the NEPA process requires public input at 

the scoping stage of Programmatic EIS development and after the publication of the Draft Programmatic 

EIS. BOEM will collect comments relevant to development of the Draft Programmatic EIS and National 

OCS Program development at public meetings, from the Federal commenting website 

www.regulations.gov, and through the U.S. mail. BOEM’s staff will attend the public meetings to 

facilitate discussions with the public on both planning processes. The Programmatic EIS will also include 

a public comment process, including responses to substantive comments on the Draft Programmatic EIS 

within the Final Programmatic EIS and, if relevant, the Proposed Program decision document. Please 

visit https://www.boem.gov/National-OCS-Program/ for public meeting locations, dates, and times. 

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Chapter 4 Background, Leasing History, and Status of OCS 

Planning Areas 

4.1 BACKGROUND 

This chapter contains the background and history of all 26 OCS planning areas upon which the DPP 

analyses are based. The OCS is divided into 26 planning areas that are grouped, for administrative 

purposes, into the following four regions (see Figures 1-2 and 1-3): 

Alaska Region. The Alaska Region is the largest OCS region, covering more than 1,035 million acres 

including offshore areas such as the Chukchi Sea, Beaufort Sea, the Bering Sea, Cook Inlet, and Gulf of 

Alaska. Water depths in the Alaska OCS range from less than 10 feet to more than 25,000 feet. This 

region consists of 15 planning areas (see Figure 1-2). Lease sales have been held in eight of the planning 

areas over the years, the most recent of which was held in 2017 in the Cook Inlet Planning Area. Four of 

the areas (Aleutian Arc, Aleutian Basin, Bowers Basin, and St. Matthew-Hall) have been determined to 

have negligible oil and gas resource potential. The only existing Federal leases are in the Beaufort Sea 

Planning Area and Cook Inlet Planning Area. There were 487 leases issued in the Chukchi Sea Planning 

Area in 2008, all of which have been relinquished. The current 2017–2022 Program includes an Alaskan 

sale (Cook Inlet Sale 258) in 2021. 

Pacific Region. The Pacific Region encompasses an area of more than 248 million acres in four planning 

areas, and includes the Pacific offshore area from the Canadian border in the north to the Mexican border 

in the south (see Figure 1-3).11 Water depths range from approximately 30 feet to more than 17,500 feet. 

Lease sales have been held in all four areas, with the most recent lease sale occurring in 1984. The 

Southern California Planning Area has existing Federal leases and production from 23 platforms. 

Gulf of Mexico Region. The GOM Region is on the southern margin of the United States and contains 

approximately 160 million acres in three planning areas. The coastline distance is approximately 

1,650 miles from Texas to the Straits of Florida (see Figure 1-3). Water depths range from less than 

30 feet to greater than 11,000 feet. The Central and Western GOM planning areas are the most mature 

and active oil and gas areas of the OCS, with production ongoing for more than 60 years. Annual 

planning area-wide lease sales in these two areas had been typical for the past 30 years. However, the 

2017–2022 Program instituted semi-annual, region-wide lease sales of all available acreage in the 

Western, Central, and Eastern GOM Planning Areas. Although much of the Eastern GOM Planning Area 

is unavailable for leasing through June 30, 2022, there are existing Federal leases in all three planning 

areas due to lease sales that occurred prior to the moratorium and in the small area of the Eastern GOM 

Planning Area that is not under moratorium. Additionally, millions of cubic yards of OCS sand for 

coastal protection projects in this region have been conveyed through leases and agreements. 

11 Administratively, the Pacific Region includes the State of Hawaii. However, for the national OCS oil and gas leasing program, 

and, in particular, DPP analysis purposes, the Pacific Region only includes the four planning areas off of the U.S. west coast. 

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Atlantic Region. The Atlantic Region encompasses an area of nearly 270 million acres in four planning 

areas. It extends north to Canada, east to the offshore territorial waters of the Commonwealth of the 

Bahamas, and south to the territorial waters of Cuba (see Figure 1-3). Water depths in the Atlantic OCS 

range from approximately 12 feet to more than 18,000 feet. Lease sales have been held in all four areas, 

the most recent of which was held in 1983. There was exploration activity in the past, but there has been 

no production in this region. There are no existing oil and gas leases in the Atlantic Region; however, 

there are 13 existing leases for renewable energy projects, and millions of cubic yards of OCS sand for 

coastal protection projects in this region have been conveyed through leases and agreements. 

Table 4-1 contains a summary of the OCS regions. See Section 7.1 for more information on the 

environmental setting of the four regions and the planning areas. The environmental setting of an area 

where oil and gas leasing activities could occur is defined by various geological, geographical, and 

ecological characteristics. Section 6.5 provides an overview of the various economic, military, and public 

uses of the OCS and nearby coastal regions. 

Table 4-1: Acreages of the OCS Regions 

Region Acres (millions) Number of 

Planning Areas 

Alaska 1,035 15 

Pacific 248 4 

Gulf of Mexico 160 3 

Atlantic 269 4 

The planning areas were initially established for administrative convenience to implement the OCS Lands 

Act Amendments of 1978. They have been reconfigured several times over the years, most recently to 

correspond to the administrative lines announced in the January 2006 Federal Register Notice 

(71 FR 127) and the February 2006 DPP for 2007–2012. Unless otherwise noted, references to a 

planning area in this document correspond to the current configuration. The portion of a planning area 

that is available for leasing consideration in the National OCS Program is referred to as a program area 

(see Part I). A program area can be an entire planning area; a small portion of a planning area; comprised 

of parts, or all, of more than one planning area; or any size/configuration in between. As discussed in the 

program development process in Chapter 1, the preparation of a new National OCS Program begins with 

an RFI and analysis and consideration of all 26 planning areas, as required by the OCS Lands Act. Once 

areas are chosen for further consideration by the Secretary, the subsequent analyses generally focus on 

those areas. 

Restrictions on OCS leasing can originate from outside the National OCS Program development process. 

Areas may be withdrawn by the President under Section 12(a) of the OCS lands Act, 43 U.S.C. 1341(a), 

and are referred to as presidential withdrawals (also referred to as executive withdrawals). Areas can also 

be withdrawn or otherwise made unavailable for leasing by the President under the Antiquities Act, or by 

Congress by such statutes as GOMESA. Recently, pursuant to E.O. 13795, President Trump reduced 

existing presidential withdrawals to include only those of the North Aleutian Basin and National Marine 

Sanctuaries that were designated as of July 14, 2008. Table 4-2 lists the areas withdrawn from OCS oil 

and gas leasing and the current status of withdrawal. 

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Table 4-2: Status of Areas Withdrawn from OCS Oil and Gas Leasing 

Area/Feature Withdrawal Date Status 

National Marine Sanctuaries 

designated as of July 14, 2008 

April 27, 2017 Unavailable for OCS oil and gas leasing, 

pursuant to the OCS Lands Act, 

43 U.S.C. 1341(a). 

Majority of the Eastern GOM 

and a portion of the Central 

GOM 

December 20, 2006 Unavailable for oil and gas leasing until 

June 30, 2022, pursuant to GOMESA. 

North Aleutian Basin (Alaska) December 16, 2014 Withdrawn. Unavailable for OCS oil and gas 

leasing, pursuant to the OCS Lands Act, 

43 U.S.C. 1341(a). 

Northeast Canyons and 

Seamounts Marine National 

Monument (Atlantic) 

September 15, 2016 Unavailable for OCS oil and gas leasing, 

pursuant to the Antiquities Act 

(54 U.S.C. 320301). 

Note: The designation and expansion of any National Marine Monument is under review pursuant to Section 4 of E.O. 13795 (April 28, 2017). 

Key: GOM = Gulf of Mexico; GOMESA = Gulf of Mexico Energy Security Act 

4.1.1 Alaska Region Planning Areas 

The Alaska Region is composed of 15 planning areas surrounding the state. Federal lease sales have been 

held in 8 of those planning areas. Existing Federal leases are present only in the Beaufort Sea Planning 

Area and the Cook Inlet Planning Area. The only Federal production is occurring in a joint Federal/state 

unit in the Beaufort Sea Planning Area. Outside of the Beaufort Sea and Cook Inlet, there is little, if any, 

existing oil and gas infrastructure and activity offshore Alaska. All Alaska areas are considered to be 

frontier areas. See Chapter 5 for information on the oil and gas resource potential in Alaska. 

Figure 9-2 shows the general position on OCS oil and gas production stated by the Governor of Alaska, as 

expressed in the comments received in response to the RFI. 

4.1.2 Beaufort Sea 

Ten lease sales have been held in this planning area since 1979. One lease sale was scheduled in the 

2012‒2017 Program, but was subsequently cancelled on October 16, 2015, due to lack of industry interest 

and then-existing market conditions. One lease sale was planned in the 2017–2022 Proposed Program, 

but was subsequently removed in the 2017‒2022 PFP decision. 

Pursuant to Section 12(a) of the OCS Lands Act, 43 U.S.C. 1341(a), on December 20, 2016, President 

Obama withdrew the majority of the Beaufort Sea Planning Area in the Alaskan Arctic from future oil 

and gas leasing consideration for a time period without specific expiration (see Figure 1-2). However, 

E.O. 13795 rescinded this withdrawal and thus the entire Beaufort Sea Planning Area is available for 

leasing consideration. 

As of December 1, 2017, there were 21 existing OCS leases in this planning area. Thirty-one exploratory 

wells have been drilled.12 The most recently drilled well (2012) was plugged and abandoned without 

being drilled to total depth. In July 2017, BOEM approved an exploration plan for up to four exploration 

wells to be drilled from an existing gravel island. BOEM currently is reviewing a development and 

production plan to build a gravel island to drill wells for producing from a discovery in this planning area. 

12 The 31 wells include the top hole well drilled in 2012, which is not considered a well drilled to completion. 

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The State of Alaska holds area-wide lease sales in the adjacent state waters annually in the fall, and there 

is active production from state acreage adjacent to existing OCS leases. 

The North Slope Borough and others, in public comments on the RFI, have stated the importance of 

ensuring adequate oil production to extend the operation of the Trans-Alaska Pipeline System (TAPS). 

TAPS is currently operating at approximately one-quarter of its capacity and requires new discoveries to 

continue operations. Both the Beaufort Sea and the Chukchi Sea planning areas have the potential for oil 

discoveries that could help extend the viability of TAPS. 

4.1.3 Chukchi Sea 

Three lease sales have been held in this area since 1988. Five exploratory wells were drilled prior to 

1992 on leases issued in earlier lease sales; all have since been plugged and abandoned. An uneconomic 

gas discovery was made in 1990 in the Burger prospect and the well was plugged and abandoned. One 

exploration well was drilled in 2012, but was also plugged and abandoned without being drilled to total 

depth. In 2015, one exploration well was drilled to total depth and has been plugged and abandoned. 

Lease Sale 193, the most recent in this area, was held in February 2008, and was the largest lease sale in 

the history of Alaska OCS leasing, generating more than $2.6 billion in bonus revenues. There are no 

existing leases; for a variety of reasons, all 487 leases in the Chukchi Sea Planning Area have been 

relinquished by the leaseholders. The Chukchi Sea Planning Area, however, has significant estimated 

hydrocarbon resource potential. 

One lease sale was scheduled in the 2012‒2017 Program, but subsequently cancelled on 

October 16, 2015, due to lack of industry interest and then-existing market conditions. One lease sale was 

scheduled in the 2017‒2022 Proposed Program but was removed in the 2017–2022 PFP decision. 

Pursuant to Section 12(a) of the OCS Lands Act, 43 U.S.C. 1341(a), on December 20, 2016, President 

Obama withdrew the entire Chukchi Sea Planning Area in the Alaskan Arctic from future oil and gas 

leasing consideration for a time period without specific expiration (see Figure 1-2). However, 

E.O. 13795 rescinded this withdrawal and the Chukchi Sea Planning Area is available for leasing 

consideration. 

4.1.4 Hope Basin 

No lease sales have been held in the Hope Basin Planning Area. The area was included in the 

1997–2002 Program as a simultaneous U.S./Russia OCS lease sale, but that sale was canceled. 

Subsequently, this area was included in the 2002–2007 Program as a special interest lease sale in 

conjunction with the Chukchi Sea Planning Area. However, no interest was expressed for the Hope Basin 

in response to three Calls issued during the 2002–2007 Program timeframe. 

4.1.5 Norton Basin 

One lease sale was held in 1983 in Norton Basin. Six exploratory wells have been drilled, with no 

commercial discoveries. There are no existing leases. The area was included in the 2002–2007 Program 

as a special interest lease sale. Four Calls were issued with no expressions of interest. 

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4.1.6 Navarin Basin 

One lease sale was held in 1983 in the Navarin Basin. Eight exploratory wells were drilled, with no 

commercial discoveries. There are no existing leases and the area has not been included in a lease sale 

schedule since the 1987–1992 Program. 

4.1.7 St. George Basin 

One lease sale was held in 1983 in St. George Basin. Ten exploratory wells were drilled, with no 

commercial discoveries. There are no existing leases in this area. One lease sale was scheduled in the 

1992–1997 Program, but it was cancelled. The area has not been included for leasing consideration since 

that National OCS Program. 

4.1.8 North Aleutian Basin 

There was one lease sale in the North Aleutian Basin in 1986 with 23 leases issued in 1988 after 

resolution of litigation concerning the lease sale. However, those leases were relinquished in settlement 

of litigation in 1995. There has been no exploratory activity and there are no existing leases in this area. 

One lease sale was scheduled for this area in the 2007–2012 Program. However, pursuant to 

Section 12(a) of the OCS Lands Act, the area was withdrawn from leasing consideration through 

June 30, 2017, by President Obama in a statement on March 31, 2010. The lease sale proposed in the 

original 2007–2012 Program was not included in the December 2010 Revised 2007–2012 Program that 

followed the remand by the U.S. Court of Appeals (see Section 2.7 for further information). 

Pursuant to Section 12(a) of the OCS Lands Act, 43 U.S.C. 1341(a), on December 16, 2014, President 

Obama withdrew the entire North Aleutian Basin Planning Area from future leasing consideration for a 

time period without specific expiration (see Figure 1-2). 

4.1.9 Cook Inlet 

There have been six lease sales in this area since 1977. As of December 1, 2017, there are 14 existing 

leases in the planning area, all of which were issued as a result of Lease Sale 244 held June 21, 2017. 

Thirteen exploratory wells have been drilled on earlier leases, with no commercial discoveries. 

The upper Cook Inlet is a mature basin in which extensive exploration and development in state 

submerged lands have occurred during the past 40 years. The State of Alaska schedules annual area-wide 

lease sales in state submerged lands, the most recent of which was held in June 2017, with bids received 

on six tracts. Annual production from non-OCS leased acreage during calendar year (CY) 2016 totaled 

approximately 5.7 million barrels of oil (bbl) (ADNR 2016) and approximately 296 billion cubic feet of 

natural gas (EIA 2017). Existing infrastructure in the upper portion of Cook Inlet includes 17 platforms 

in state waters, associated oil and gas pipelines, and onshore drill pads, processing and support facilities. 

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4.1.10 Gulf of Alaska 

Three lease sales were held from 1976 to 1981 in the Gulf of Alaska. Twelve exploratory wells were 

drilled, but no commercial discoveries have been found. The lease sale scheduled in the 

1997–2002 Program was canceled, primarily due to low prices and low industry interest. There are no 

existing leases. 

4.1.11 Alaska Planning Areas with No Lease Sales 

The following planning areas have had no lease sales and no wells have been drilled: 

• Aleutian Arc 

• Aleutian Basin 

• Bowers Basin 

• Hope Basin 

• Kodiak 

• Shumagin 

• St. Matthew-Hall. 

4.2 PACIFIC REGION PLANNING AREAS 

The Pacific OCS planning areas encompass more than 248 million acres, and includes the Pacific offshore 

area extending north to the Canadian border and south to the Mexican border. Pacific OCS planning 

areas begin 3 miles offshore and extend seaward to approximately 200 nm seaward of the baseline, with 

water depths ranging from approximately 30 feet to more than 17,500 feet. 

The Pacific Region is comprised of four planning areas: Washington/Oregon, Northern California, 

Central California, and Southern California. Lease sales have been held in all four planning areas, the 

most recent of which was held in 1984. There are existing leases and production from these leases in the 

Southern California Planning Area. See Chapter 5 for information on the Pacific Region oil and gas 

resource potential. Figure 9-2 shows the general positions stated by the governors of the three coastal 

states, as expressed in their comments received in response to the RFI. 

4.2.1 Washington/Oregon 

One lease sale was held in 1964 in the Washington/Oregon Planning Area. Twelve exploratory wells 

were drilled, with no commercial discoveries. There are no existing leases. The area was under annual 

Congressional restrictions from Fiscal Year (FY) 1991 through FY 2008, and under presidential 

withdrawal from 1990 to July 2008. 

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4.2.2 Northern California 

One lease sale was held in 1963 in Northern California. Seven exploratory wells were drilled, with no 

commercial discoveries. The area was under annual Congressional restrictions from FY 1982 through 

FY 2008 and under presidential withdrawal from 1990 to July 2008. 

4.2.3 Central California 

One lease sale was held in 1963 in Central California. Twelve exploratory wells were drilled, with no 

commercial discoveries. The area was under annual Congressional restrictions from FY 1991 through 

FY 2008 and under presidential withdrawal from 1990 to July 2008. Most of the OCS closest to the coast 

is designated as National Marine Sanctuaries (NMSs) and is under presidential withdrawal for a time 

period without specific expiration. 

4.2.4 Southern California 

Ten lease sales were held from 1963 through 1984 for Southern California. More than 1,500 exploratory 

and development wells have been drilled. As of December 1, 2017, there are 43 existing leases, all 

considered producing. Oil and gas production, which began in June 1968, totaled more than 1.35 billion 

barrels of oil (BBO) and 1.84 trillion cubic feet (Tcf) of natural gas through December 2016. Much of the 

area was under annual Congressional restrictions for new lease sales from FY 1985 through FY 2008 and 

under presidential withdrawal from 1990 until July 18, 2008. There also are producing leases in state 

waters, although no new state leases have been issued since 1969. 

4.3 GULF OF MEXICO REGION PLANNING AREAS 

The GOM Region is comprised of the Western, Central, and Eastern GOM planning areas. The Western 

and Central GOM planning areas are the most mature and active of all the 26 OCS planning areas, with 

extensive existing infrastructure. The GOM’s Western and Central GOM planning areas, consisting of 

the OCS offshore Alabama, Mississippi, Louisiana, and Texas, remain the primary offshore source of oil 

and gas for the United States, generating about 98 percent of all OCS oil and gas production. This high 

level of production and activity is supported by an oil and gas industry that includes hundreds of large and 

small companies, and an expansive onshore network of coastal infrastructure. The majority of the Eastern 

GOM Planning Area and a small portion of the Central GOM Planning Area are not available for leasing 

consideration through June 30, 2022, pursuant to GOMESA. There are existing leases in both the 

currently available and unavailable portions of the Eastern GOM. Those in the unavailable portion 

pre-date the GOMESA restriction. 

The geology of the GOM basin and the complexity and abundance of its salt structures provides the 

setting that makes the GOM one of the richest oil and natural gas regions in the world. The greatest 

undiscovered resource potential in the OCS is forecast to exist in the deep and ultra-deep waters of the 

GOM. 

There have been more than 100 lease sales since 1953 in the GOM Region. There is production from 

leases in the Western and Central GOM planning areas, but as of December 1, 2017, no production has 

occurred from leases anywhere in the Eastern GOM Planning Area. See Part III for geologic play maps 

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and a discussion of estimated oil and gas resources by planning area. Figure 9-2 shows the general 

position on OCS oil and gas production stated by governors in the GOM Region, as expressed in the 

comments received in response to the RFI. 

Internationally, the U.S and Mexico signed the Agreement between the United States of America and the 

United Mexican States Concerning Transboundary Hydrocarbon Reservoirs in the Gulf of Mexico 

(Agreement) in February 2012. It entered into force in July 2014. The Agreement sets out a framework 

for cooperating on joint exploration and exploitation of geological hydrocarbon structures and reservoirs 

that extend across the maritime boundary of the U.S. and Mexico, and the entirety of which are located 

beyond nine miles from the coastline. Accordingly, the U.S. and Mexico notify each other of planned 

activities within three statute miles of the limitation line. Mexico made constitutional amendments in 

December 2013, followed by legislation in August 2014, which opened oil and natural gas markets to 

foreign investments, including from entities that are active in the GOM. The first leases in the area 

covered by this agreement on the U.S. side were issued from Western GOM Lease Sale 238, held in 

August 2014. The opening of Mexican waters could provide for long-term expansion of U.S.-Mexico 

energy trade and opportunities for U.S. companies, but also could result in a short- or longer-term shift in 

investment focus to the Mexican waters from the OCS. 

4.3.1 Western Gulf of Mexico 

As of December 1, 2017, there are approximately 437 existing leases in the Western GOM. More than 

7,800 wells have been drilled. The most recent and first region-wide lease sale, Lease Sale 249, was held 

on August 16, 2017, and resulted in 23 Western GOM tracts being bid on with high bid bonuses totaling 

almost $38 million. The State of Texas administers a robust oil and gas program in state submerged lands 

adjacent to this area. 

4.3.2 Central Gulf of Mexico 

As of December 1, 2017, there are approximately 2,356 existing leases in the Central GOM. More than 

44,743 wells have been drilled. The most recent and first region-wide lease sale, Lease Sale 249, was 

held on August 16, 2017, and resulted in 67 Central GOM tracts being bid on with high bid bonuses 

totaling more than $82 million. The states of Louisiana and Alabama administer robust oil and gas 

programs in state submerged lands adjacent to this area. There are no leases in Mississippi state 

submerged lands. 

4.3.3 Eastern Gulf of Mexico 

As of December 1, 2017, there are 37 existing leases in this area. Fourteen lease sales have been held in 

this planning area as it has been configured over the years and more than 100 wells drilled, with 

significant discoveries of natural gas. However, there has been no production in the planning area. The 

majority of this planning area is unavailable for leasing consideration through June 30, 2022, pursuant to 

GOMESA’s moratorium. Lease Sale 224 in March 2008, a sale mandated by GOMESA, resulted in 

leases being awarded on 36 OCS blocks with bonuses totaling $64.7 million. The most recent sale for the 

Eastern GOM, part of BOEM’s first region-wide lease sale, Lease Sale 249, was held on 

August 16, 2017. No bids were received on tracts in the available area of the Eastern GOM. 

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4.4 ATLANTIC REGION PLANNING AREAS 

The Atlantic OCS encompasses nearly 270 million acres, and includes the Atlantic offshore area 

extending north to Canada, east to the offshore territorial waters of the Commonwealth of the Bahamas, 

and south to the offshore territorial waters of Cuba. The area begins 3 miles off the Atlantic coast and 

extends at least to the edge of EEZ and beyond, where the continental shelf extends beyond the EEZ. 

Water depths in the Atlantic OCS range from approximately 12 feet to more than 18,000 feet. 

The Atlantic Region is comprised of four planning areas (North Atlantic, Mid-Atlantic, South Atlantic, 

and the Straits of Florida) that have undergone numerous boundary changes over the years. There have 

been 10 Federal oil and gas lease sales in all or portions of this region, the most recent of which was held 

in 1983. A total of 410 leases were issued in the Atlantic, but there have been no active oil and gas leases 

since the mid-1990s, and although there were 51 wells drilled, there has been no hydrocarbon production 

from the Atlantic OCS. See Figure 5-6 for a map of the Atlantic geologic plays and oil and gas resource 

potential by planning area. Figure 9-2 shows the general positions stated by the governors of the coastal 

states, as expressed in comments received in response to the RFI. 

The Final Atlantic G&G Programmatic EIS (BOEM 2014) was published on March 7, 2014, and the 

ROD was signed on July 7, 2014, with a Notice of Availability of the ROD published in the 

Federal Register on July 23, 2014 (79 FR 42815). In accordance with Secretarial Order 3350 

(May 1, 2017), which implements President Trump’s America-First Offshore Energy Strategy, the 

USDOI will move forward in its evaluation of applications from six companies seeking permits to 

conduct G&G activities in the Atlantic Ocean. In 2017, the Acting BOEM Director reversed an earlier 

decision that summarily denied these G&G permit applications. Thus, at this time, several applications 

for G&G permits in the Atlantic are pending.13 See Chapter 5 regarding resource potential and G&G 

activities. 

4.4.1 North Atlantic 

Between 1976–1984, 43 exploratory wells were drilled in the currently configured planning area with no 

commercial discoveries. The area was under annual Congressional restrictions from FY 1984 through 

2008, and under presidential withdrawal from 1990 through July 18, 2008. There are no existing oil and 

gas leases. There are eight renewable energy leases. The northern section of this planning area is 

adjacent to the offshore waters of the Canadian province of Nova Scotia, where there are existing 

exploratory permits. However, those that abut the U.S.-Canada boundary are within the Georges Bank 

Prohibited Zone, as declared by the Canada federal, and Nova Scotia, governments, where no activity is 

allowed to occur in Canadian waters through the end of 2022. 

4.4.2 Mid-Atlantic 

In 1984, one exploratory well was drilled in the current planning area, with no commercial discoveries. 

There are no existing oil and gas leases. There are five renewable energy leases. The area was subject to 

presidential withdrawal from June 1998 to July 2008 and to annual Congressional restrictions from FY 

1999 through FY 2008. A special interest lease sale for an area offshore Virginia was scheduled for 2011 

13 See BOEM’s website for updates: https://www.boem.gov/Atlantic-G-and-G-Permitting/. 

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in the 2007–2012 Program; however, the lease sale was cancelled by the Secretary in May 2010, and a 

notice of cancellation published in the Federal Register on July 28, 2010 (75 FR 44276). This planning 

area was analyzed in the Atlantic G&G Programmatic EIS and the Draft Programmatic EIS for the 

2017–2022 Program, and G&G permit applications for the area are under review. A potential lease sale 

for a portion of this planning area was included in the 2017–2022 DPP decision, but subsequently 

removed in the 2017–2022 Proposed Program decision. 

4.4.3 South Atlantic 

Between 1979–1980, seven exploratory wells were drilled in the current planning area with no 

commercial discoveries. The area was subject to presidential withdrawal from 1998 to July 2008 and to 

annual Congressional restrictions from FY 1999 through FY 2008. This planning area was analyzed in 

the Atlantic G&G Programmatic EIS and the Draft Programmatic EIS for the 2017–2022 Program, and 

G&G permit applications for the area are under review. A potential lease sale for a portion of this 

planning area was included in the 2017–2022 DPP decision, but subsequently removed in the 2017–2022 

Proposed Program decision. 

4.4.4 Straits of Florida 

Between 1960–1961, three exploratory wells were drilled, with no commercial discoveries. There are no 

existing oil and gas or renewable energy leases and the area has not been included in a National OCS 

Program since 1987–1992. No Congressional or Presidential restrictions on activity have been in place. 

There are existing exploratory licenses offshore Cuba and the Commonwealth of the Bahamas in the 

waters nearby to this planning area. Wells that were drilled in the past off both countries have not had 

commercial discoveries. In June 2014, Cuba signed agreements with Russian companies to further 

explore in Cuban waters. In 2017, Cuba ramped up its solicitation of foreign investment in its offshore, 

which is primarily in deep and ultra-deep water. Interest has been expressed by companies from 

Australia, Venezuela, Angola, and Canada. An exploration well could be drilled offshore the Bahamas in 

the next year by the Bahamas Petroleum Company. 

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Part III: Analysis and Results 

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Chapter 5 Valuation of Planning Areas 

5.1 ESTIMATING HYDROCARBON RESOURCES 

Oil and gas resource assessments are critical components of energy policy analysis and provide important 

information about the relative potential of U.S. offshore areas as sources of oil and natural gas. In 

particular, they provide the Secretary with information on the geological characteristics of OCS regions, 

as required by Section 18(a)(2)(A) of the OCS Lands Act. For the DPP analysis, BOEM considers the 

amount of undiscovered economically recoverable oil and gas resources (UERR) available on unleased 

blocks in each of the OCS planning areas as part of the valuation and ranking process (i.e., areas are 

ranked from greatest to least amount of resources estimated to be economically recoverable). BOEM’s 

approach to resource assessment is designed to account for the uncertainty inherent in estimating 

undiscovered resources. 

In general, uncertainty in estimates of undiscovered oil and natural gas is greatest for frontier areas that 

have had little or no past exploratory effort (e.g., the Arctic). For areas that have been extensively 

explored and are in a mature development stage (e.g., the Central GOM Planning Area), many of the 

developmental risks have been reduced and the degree of uncertainty reflected in the range of possible 

outcomes has been narrowed. 

In conducting resource assessments, BOEM accounts for this uncertainty by applying risk to geologic 

plays and assessment units that do not have a proven petroleum system. BOEM subsequently reports 

estimates of undiscovered technically recoverable resources (UTRR) as “risked.” The opportunity to drill 

wells in frontier areas can provide the empirical evidence necessary to determine the presence of 

hydrocarbons within the assessment units or geologic plays in these areas. In the event that hydrocarbons 

are encountered through well drilling, these geologic risks would be eliminated, resulting in a dramatic 

increase in UTRR estimates reported by BOEM in these frontier areas. For example, based on the 

Assessment of Undiscovered Oil and Gas Resources of the Nation’s Outer Continental Shelf, 2016 

(BOEM 2016a), referred to as the “2016 National Assessment,” the elimination of all petroleum system 

risk from conceptual plays on the Atlantic OCS could increase BOEM’s reported UTRR estimates by as 

much as 300 percent, which translates to a very significant upside regarding oil and gas resource potential 

on the Atlantic OCS. 

Where possible, BOEM considers recent geophysical, geological, and technological information to 

estimate the potential presence and amount of technically recoverable oil and gas resources on the OCS. 

BOEM also considers economic parameters, such as exploration and development costs and oil and gas 

prices, to estimate the economically recoverable resources on the OCS. Current BOEM oil and gas 

resource estimates come from the 2016 National Assessment. These estimates form the basis for the 

unleased UERR used in the economic analysis provided in this chapter. 

5.2 INTRODUCTION TO HYDROCARBON RESOURCES ON THE OCS 

Each of the OCS regions comprises geologic characteristics and petroleum system elements that provide 

an opportunity for the existence of oil and gas resources. Oil and gas are thermally generated as organic 

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matter changes in composition with increasing burial depth and temperature. Once generated and 

expelled from source rocks, the hydrocarbons migrate laterally and/or vertically into porous reservoirs 

that are associated with an impermeable trap or seal. 

These petroleum system elements are not ubiquitous across the entire OCS. Thus, the assessment of 

hydrocarbon resources requires that geologic plays be delineated, which allows for the incorporation of 

petroleum system elements that reflect local geologic conditions. A geologic play is a group of 

geologically related potential or known hydrocarbon accumulations that share a common history of 

hydrocarbon generation, accumulation, and entrapment in a reservoir. BOEM defines two types of 

geologic plays in its resource assessment, as follows: 

• established play: geologic play in which hydrocarbons have been discovered and a petroleum 

system has been proven to exist 

• conceptual play: geologic play in which hydrocarbons have not been detected, but for which 

G&G data, integrated with regional geologic knowledge, suggest that hydrocarbon accumulations 

could exist. 

Geologic plays consist of oil and gas pools, where a pool is defined as a discovered or undiscovered 

accumulation of hydrocarbons. In many instances, a prospect (if undiscovered) or a field (if discovered) 

will comprise one or more pools. A prospect or field is an area consisting of a single reservoir or multiple 

reservoirs all grouped on, or related to, a shared geologic structural feature and/or stratigraphic trap. 

Figures 5-1 through 5-6 show the geologic plays analyzed in the 2016 National Assessment. Most plays 

are defined on the basis of reservoir-rock stratigraphy and are delineated by the extent of the reservoir 

rocks; however, a few plays are defined on the basis of structural characteristics of prospective traps. 

Plays could overlap spatially because they exist at different depths below the sea floor and, in many cases, 

are stacked on top of each other. Therefore, the figures showing geologic play outlines do not represent 

the full, 3-D extent of an individual geologic play. 

5.2.1 Resource Commodities Assessed 

BOEM assesses crude oil, natural gas liquids (condensate), and natural gas that exist in conventional 

reservoirs and are producible with conventional recovery techniques. Crude oil and condensate are 

reported jointly as billion barrels of oil; natural gas is reported in aggregate as trillion cubic feet (Tcf) of 

gas. Oil-equivalent gas is a volume of gas expressed in terms of its energy equivalence to oil (i.e., 

5,620 cubic feet of gas per barrel of oil). The combined volume of oil and oil-equivalent gas resources is 

referred to as barrel of oil equivalent (BOE) and is reported in billion barrels of oil equivalent (BBOE). 

The technically and economically recoverable resources forecasted by BOEM do not include potentially 

large quantities of hydrocarbon resources that could be recovered by enhanced recovery techniques. 

Furthermore, these assessments do not consider gas in geopressured brines, methane hydrates, or oil and 

natural gas that could be present in insufficient quantities or quality (low-permeability, “tight” reservoirs) 

to be produced by conventional recovery techniques. 

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Figure 5-1: Extent of Geologic Plays in the Beaufort Sea and Chukchi Sea Planning Areas 

Figure 5-2: Extent of Geologic Plays in the North Aleutian Basin Planning Area 

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Figure 5-3: Extent of Geologic Plays in the Cook Inlet and Gulf of Alaska Planning Areas 

Figure 5-4: Extent of Geologic Plays in the Pacific Region Planning Areas 

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Figure 5-5: Extent of Geologic Plays in the Gulf of Mexico Region Planning Areas 

Figure 5-6: Extent of Geologic Plays in the Atlantic Region Planning Areas 

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5.2.2 Sources of Data and Information 

Estimating undiscovered oil and gas resources on the OCS is a complex process and requires the 

incorporation of a variety of geological, geophysical, economic, and engineering data. The petroleum 

geologic characteristics (i.e., volumes and qualities of source rocks, reservoir rocks, and traps) of plays 

are defined using play-specific information from wells, seismic-reflection profiles, and/or analogous 

information from geologically similar reservoirs in other parts of the world. In areas where oil and gas 

production is from mature plays (such as established plays in the GOM), data and information typically 

are derived from producing reservoirs and fields within the play. In these cases, volumetric estimates of 

discovered oil and gas pools within the play are used to develop probability distributions for the size and 

number of undiscovered pools and fields in assessment areas. 

Due to sparse data directly associated with BOEM’s conceptual plays in the Alaska and Atlantic regions, 

analog-based parameters are developed using professional judgment to cover the range of uncertainties 

associated with these plays. The analog development process includes extensive research into the 

geological, geophysical, geochemical, and lithological characteristics of productive oil/gas discoveries in 

analogous plays. Specific information analyzed within analog plays includes the style of oil and/or gas 

trap, reservoir depositional environment and lithology, reservoir age, and analysis of existing drilling and 

well bore information. Conceptual play models are developed using regional G&G data. 

5.2.3 Geophysical Data Collection (Seismic Surveys) 

Geophysical (seismic) surveying is a method of mapping below the seafloor using sound waves. The 

sound waves are generated using acoustic energy from air guns that release bursts of compressed air, 

which are reflected back from rock layers below the seafloor and recorded. Geophysicists use these data 

to identify areas favorable for the accumulation of hydrocarbons. 

Geophysical data provide important information for oil and gas resource assessments. Two-dimensional 

(2-D) seismic surveys often are designed to cover thousands of square miles or entire geologic basins as a 

means to assess large areas for hydrocarbon potential. In contrast, 3-D surveys can focus on a few to 

several hundred OCS blocks and provide higher resolution to evaluate hydrocarbon potential in 

structurally complex areas (often below salt) that may be poorly imaged on existing 2-D seismic surveys. 

In general, the acquisition and processing of marine seismic data is a complex process that often requires 

a significant time and cost investment measured in years and millions of dollars. 

BOEM maintains an inventory of industry seismic data that includes more than 308,000 OCS blocks of 

3-D coverage and 3.1 million line-miles of 2-D coverage. The distribution of seismic data over OCS 

regions is generally coincident with the maturity of existing oil and gas development in the regions. For 

example, more than 99 percent of the 3-D seismic data and approximately 74 percent of the 2-D seismic 

data on the OCS have been acquired in the GOM. 

5.2.4 Uncertainty in Resource Assessment 

All methods of assessing potential quantities of technically and economically recoverable resources are 

efforts in quantifying a value that will not be reliably known until the resource is nearly depleted. Thus, 

there is considerable uncertainty intrinsic to any estimate, and resource estimates should be used as 

general indicators and not predictors of absolute volumes. Some of the uncertainty is regarding the 

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presence and quality of petroleum source rocks, reservoir rocks, seal rocks, and traps; the timing of 

hydrocarbon generation, migration, and entrapment; and the location, number, and size of accumulations. 

The value and uncertainty regarding these petroleum geologic factors are often expressed qualitatively. 

However, to develop volumetric resource estimates, the value and uncertainty regarding these factors 

must be expressed quantitatively. Each of these factors, and the volumetric resource estimate derived 

from them, is expressed as a range of values, with each value having a corresponding probability. For the 

purpose of the DPP analysis, only the mean estimates of unleased UERR are used. 

For this DPP analysis, estimates of unleased UERR are derived from a geologic play-based approach that 

spans large geographic areas. This approach differs from that which is used for individual OCS tract 

evaluations to determine the FMV of OCS blocks receiving bids in a particular lease sale. For the 

sale-specific evaluations, a more detailed prospect analysis is performed and subsequently subjected to 

economic parameters and fiscal regimes specific to the timing and location of that particular lease sale. 

As mentioned in Section 5.1, BOEM accounts for uncertainty by applying risk to geologic plays and 

assessment units where a working petroleum system has not been proved and subsequently reports 

estimates of UTRR as “risked.” In the event that hydrocarbons are encountered through well drilling, 

these risks would be eliminated, resulting in a dramatic increase in UTRR estimates reported by BOEM in 

these frontier areas. To illustrate the influence of geologic risk on reported UTRR estimates, 

Figure 5-7 shows the magnitude of the upside UTRR potential on the Atlantic OCS if all petroleum 

system risk in conceptual plays were removed through successful drilling and field discovery. 

Figure 5-7: Risked versus Undiscovered Resource Potential for the Atlantic OCS 

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5.2.5 Resource Assessment Methodology and Output 

The general methodology that BOEM utilizes to assess undiscovered oil and natural gas resources on the 

OCS is a multi-step process using existing data, professional judgment, and probability distributions in 

conjunction with the Geologic Resource Assessment Program (GRASP) model. GRASP is a geologic 

play-based model that compiles oil and gas play data to generate a range of values of undiscovered 

resources for each geologic play. 

The execution of the GRASP model is comprised of the following steps to assess oil and gas resources on 

the OCS: 

1. Compile play data. 

2. Generate a cumulative probability distribution of pool sizes from probabilistic distributions of 

reservoir parameters. 

3. Generate a number of pools probability distribution. 

4. Determine the probabilities for individual oil, natural gas, and mixed pool types. 

5. Establish individual pool size estimates and compare to the ranked sizes of discovered pools. 

6. Generate potential resources of the play. 

Volumetric estimates of UTRR and UERR are based on the geologic and petroleum engineering 

information developed through petroleum geological analysis and quantified through play analysis. 

These estimates are developed in two stages. First, UTRR are assessed for each play, where UTRR are 

defined as oil and gas that could be produced using conventional extraction techniques without any 

consideration of economic viability. 

The UTRR estimates from the 2016 National Assessment provide the foundation from which UERR 

estimates are derived for the DPP analysis. The mean UTRR for each planning area is shown in 

Figure 5-814. The 2016 National Assessment is available at https://www.boem.gov/National-Assessment2016/. 

Following assessment of the UTRR, economic and petroleum engineering factors are included for each 

assessment area to estimate the portion of the UTRR that is economically recoverable over a broad range 

of commodity prices. UERR are defined as the portion of the UTRR that are economically recoverable 

under specified economic and technologic conditions, including prevailing prices and costs. The 

economic portion of the assessment incorporates a wide range of oil and gas price points15 and uses a 

relationship between the cost of exploration and development and commodity prices. Estimates of UERR 

are derived for each designated oil-gas price pair using the following methodology: 

• subjecting the distributions to multiple computer iterations simulating the development of the 

hydrocarbon accumulations associated with the areas 

• performing a discounted cash flow analysis to determine the area’s economically recoverable 

resources using specified economic parameters. 

14 Pursuant to Secretarial Order 3352, BOEM is updating its assessment of nearshore Beaufort Sea resources based on new data 

from seismic surveys and drilling onshore and in state waters.

15 Because oil and gas typically are produced together, BOEM estimates UERR at specific combinations of oil and gas prices, or 

“price pairs.” 

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Figure 5-8: Assessment of UTRR on the OCS, 2016 

Note: UTRR include leased and unleased areas. Because geologic plays within the Straits of Florida are extensions of plays in the Eastern 

GOM, the UTRR for the Straits of Florida are included in GOM estimates. 

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5.2.6 Unleased Undiscovered Economically Recoverable Resources 

The DPP analysis requires an assessment of the UERR that are expected to be available for lease as of 

July 2019. BOEM considers the unleased UERR as of June 2017 as a proxy for this projection. In all 

OCS planning areas with active leases, BOEM takes into account leases that are expected to expire 

between June 2017 and July 2019 when developing unleased UERR estimates for the DPP. 

This analysis follows a multi-step process listed below and is shown in Figure 5-9: 

1. Assess all oil and gas that could be produced using conventional extraction techniques without 

any consideration of economic viability (this is the UTRR, as published in BOEM 2016a). 

2. Reduce the UTRR to that portion of oil and gas resources that is economically recoverable under 

specified economic and technologic conditions, including prevailing prices and costs (this is the 

UERR, as published in BOEM 2016a). 

3. Further reduce the UERR to only the portion expected to be available for lease as of July 2019. 

Figure 5-9: Conceptual Workflow Showing Transition from UTRR to Anticipated Production 

Note: For this DPP, only the unleased UERR (shown in pink) was considered for analysis. Anticipated production is 

considered for analysis in the subsequent Proposed Program and PFP. 

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Figure 5-10 shows the relative ranking of the planning areas based on the estimates of unleased UERR in 

BOE for an inflation-adjusted oil price of $100/bbl and an inflation-adjusted natural gas price of 

$5.34/thousand cubic feet (mcf).16 The planning areas are ranked from those with the largest amount of 

resources to those with the least. These UERR-based rankings take into account the geologic risk 

associated with finding oil and gas on the OCS. As explained in Section 5.2.4, the UERR estimates 

associated with underexplored and/or underdeveloped areas on the OCS would significantly increase 

following successful well drilling and field discovery. BOEM analyzed all 26 planning areas for resource 

potential. Eleven planning areas, preliminarily analyzed and estimated to have negligible resources or 

negligible development value, are not analyzed further in the DPP hydrocarbon and economic analyses. 

Of these 11 planning areas, seven areas have measured resource potential, but negligible development 

value. These are the St. George Basin, Kodiak, Shumagin, Navarin, Norton, and Hope Basin planning 

areas in the Alaska Region, and the Straits of Florida Planning Area in the Atlantic Region. Four of the 

planning areas (Aleutian Arc, Aleutian Basin, Bowers Basin, and St. Matthew-Hall planning areas, all in 

the Alaska Region) are excluded from the further DPP hydrocarbon and economic analysis because they 

are estimated to contain negligible resource quantities. 

To account for some of the uncertainty surrounding oil and natural gas prices and the possibility that 

prices can change greatly during development and implementation of a National OCS Program, the DPP 

analysis is conducted using three different price scenarios and corresponding sets of resource estimates. 

The unleased UERR for the 22 OCS planning areas with non-negligible resource estimates are displayed 

in Table 5-1 at the three different price scenarios. The price scenarios are based on price pairs of $40/bbl 

($2.14/mcf), $100/bbl ($5.34/mcf), and $160/bbl ($8.54/mcf). 17 The estimate of resources is provided at 

each of these three price cases to show the different level of available resources at three different sets of 

energy market conditions/activity levels. The price scenarios are discussed in more detail in Appendix B. 

Table 5-1 shows the ranking of the planning areas in order of unleased BOE resources in the $100 oil 

price case. All values in table are reported in BBOE. 

16 Prices are discussed in Price Level Assumptions in Appendix B. BOEM uses three inflation-adjusted price cases to represent 

the great uncertainty in oil and natural gas price levels. Values shown in the figure are in BBOE. 17 The price pairs reflect possible levels over the life of production from the National OCS Program rather than near-term prices, 

and the mid-range price is roughly comparable to EIA’s projections for the 15–20 years after the early sales would occur 

(EIA 2017). 

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Figure 5-10: Unleased UERR by Planning Area ($100 Oil Price Case) 

Notes: The $100 price case assumes an inflation-adjusted price of $100/bbl for oil and $5.34/mcf for natural gas over the 

life of the 2019–2024 Program. Aleutian Arc, Aleutian Basin, Bowers Basin, and St. Matthew-Hall planning areas are 

estimated to contain negligible resource quantities and are not shown in this figure. 

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USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Table 5-1: Unleased UERR as of July 2019, Ranked by BOE for the $100 Oil Price Case 

Rank Planning Area 

Oil (Bbo) Gas (Tcf) BOE (Bboe) 

$40/bbl, 

$2.14/mcf 

$100/bbl, 

$5.34/mcf 

$160/bbl, 

$8.54/mcf 

$40/bbl, 

$2.14/mcf 

$100/bbl, 

$5.34/mcf 

$160/bbl, 

$8.54/mcf 

$40/bbl, 

$2.14/mcf 

$100/bbl, 

$5.34/mcf 

$160/bbl, 

$8.54/mcf 

1 Central GOM 17.20 20.99 21.90 26.46 43.95 49.49 21.91 28.81 30.71 

2 Chukchi Sea 0.07 9.25 12.61 0.06 22.58 40.63 0.08 13.27 19.84 

3 Western GOM 6.99 8.69 9.10 14.91 25.68 28.76 9.64 13.26 14.22 

4 Beaufort Sea 1.02 6.06 7.07 0.66 8.07 12.61 1.13 7.50 9.31 

5 Southern California 2.45 3.58 3.87 3.47 4.84 5.26 3.07 4.44 4.81 

6 Eastern GOM 2.55 3.06 3.19 5.14 6.91 7.65 3.46 4.29 4.55 

7 Mid-Atlantic 1.89 2.18 2.25 2.41 7.42 10.29 2.32 3.50 4.08 

8 North Atlantic 1.48 1.64 1.68 2.45 5.05 6.24 1.92 2.54 2.79 

9 Central California 1.63 2.08 2.18 1.71 2.17 2.27 1.93 2.47 2.58 

10 Northern California 0.83 1.34 1.50 0.91 1.52 1.77 0.99 1.61 1.81 

11 Cook Inlet 0.81 0.98 1.00 0.33 0.77 1.03 0.87 1.12 1.18 

12 Gulf of Alaska 0.00 0.31 0.47 0.01 1.62 2.73 0.00 0.60 0.96 

13 North Aleutian 

Basin 0.33 0.51 0.55 0.13 0.34 0.86 0.35 0.57 0.70 

14 Washington/Oregon 0.14 0.23 0.26 0.46 0.79 0.93 0.22 0.37 0.43 

15 South Atlantic 0.09 0.18 0.22 0.20 0.52 0.69 0.13 0.27 0.34 

16 St. George Basin 0.02 0.10 0.13 0.02 0.15 0.66 0.02 0.13 0.25 

17 Hope Basin 0.01 0.06 0.08 0.02 0.17 0.90 0.01 0.09 0.24 

18 Navarin Basin 0.00 0.05 0.07 0.00 0.12 0.30 0.00 0.07 0.12 

19 Straits of Florida 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 

20 Kodiak 0.00 0.00 0.02 0.00 0.02 0.54 0.00 0.00 0.12 

21 Norton Basin 0.00 0.00 0.01 0.00 0.00 0.40 0.00 0.00 0.08 

22 Shumagin 0.00 0.00 0.00 0.00 0.00 0.02 0.00 0.00 0.00 

Note: All price scenarios represent a constant, inflation-adjusted price throughout the life of the 2019–2024 Program. The Aleutian Arc, Aleutian Basin, Bowers Basin, and 

St. Matthew-Hall planning areas contain negligible hydrocarbon resources and are not shown in this table. 

Key: Bbo= billion barrels of oil; bbl=barrels of oil, BBOE=billion barrels of oil equivalent, BOE=barrel of oil equivalent, mcf=thousand cubic feet of natural gas, Tcf=trillion 

cubic feet of natural gas, UERR=undiscovered economically recoverable resources. 

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USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Figure 5-11 shows the portion of total unleased UERR for each of the 15 fully analyzed planning areas at 

the $100 oil price case. The three GOM planning areas (Central, Western, and Eastern) contain 

55 percent of the total $100 oil price case UERR, with 34 percent of the total unleased UERR in the 

Central GOM Planning Area. The five Alaska planning areas included herein contain approximately 

27 percent of the total unleased UERR, with the Alaskan Arctic (Beaufort Sea and Chukchi Sea planning 

areas) containing 25 percent.18 The four Pacific planning areas (Washington-Oregon, Northern 

California, Central California, and Southern California) contain 11 percent, and the three Atlantic 

planning areas (South, Mid-, and North Atlantic) contain 7 percent. 

Figure 5-11: Unleased UERR by Planning Area ($100 Oil Price Case) 

Notes: St. George Basin, Kodiak, Navarin Basin, Hope Basin, Shumagin, Norton Basin, and Straits of Florida planning areas are excluded from 

this figure because they have only negligible development value and less than 0.5 percent of available UERR. Aleutian Arc, Aleutian Basin, 

Bowers Basin, and the St. Matthew-Hall planning areas are estimated to have only negligible resources and are excluded from this figure. 

Numbers may not sum due to rounding. 

5.2.7 Exploration and Development Scenarios 

Because the DPP analyses are conducted before the first programmatic decision (the DPP decision), 

BOEM provides the Secretary with relative rankings of planning areas, based on estimated unleased 

UERR quantity and value.19 These rankings will assist the Secretary in his decision as to which planning 

areas should be further considered in the preparation of the new National OCS Program. To estimate the 

social value of planning area resources, it is necessary to calculate both the economic value and the social 

costs of obtaining them. To estimate these costs, BOEM constructs exploration and development (E&D) 

scenarios, which describe the development and production activities required to explore for, extract, and 

transport to market the resources estimated within a planning area. To avoid presupposing Secretarial 

decisions on the timing of lease sales, the scenarios assume that all currently available (unleased) UERR 

18 Numbers do not sum to 100 percent due to rounding. 19 Subsequent analysis performed at the Proposed Program and PFP stages focus on the value of production and related activities 

anticipated to result from each decision option, based on forthcoming Secretarial decisions. 

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USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

are leased during the initial year of the National OCS Program (2019) and then explored, developed, and 

produced expeditiously while taking into account the basic constraints (for example, available 

infrastructure, seasonal closures) of the particular region. For the DPP analyses, three E&D scenarios are 

constructed for each of the 15 planning areas with estimated development value, based on the full 

unleased UERR within each planning area. The three scenarios reflect different sets of assumptions 

regarding prevailing oil and gas prices. The E&D scenarios provide a quantitative analysis of activities 

expressed in aggregated terms. Some examples include exploration wells drilled, production wells 

drilled, platforms installed and removed, pipelines installed, and oil and gas produced at the $40, $100, 

and $160 oil price cases. The aggregate values and scenarios are calculated by assuming hypothetical 

schedules of activities that recognize historical trends and regional differences. The schedules of 

activities cover exploration, development, production, and transportation of the UERR. The activity 

estimates derived from the E&D scenarios are used for the comprehensive analyses that describe the 

range of direct and indirect social, economic, and environmental impacts that could result from lease sales 

proposed in the National OCS Program. Historical leasing trends, drilling trends, oil and gas discovery 

volumes, production activity, and other BOEM shortterm forecasts are analyzed to generate the data and 

information used in the development of E&D scenarios. 

The DPP decision is the initial decision for the National OCS Program development process. All 

subsequent analyses (i.e., for the Proposed Program and PFP) require E&D scenarios based on anticipated 

production for the specified Program Options rather than the UERR. Table 5-2 provides a summary of 

the differences in foundational composition of the E&D scenarios for each of the program development 

phases. 

Table 5-2: Development of Oil and Gas Exploration and Development Scenarios 

National OCS Program 

Analytical Phase E&D Scenario Description 

Draft Proposed Program E&D scenarios are based on all UERR in all unleased blocks in 

all 15 planning areas. 

Proposed Program E&D scenarios are based on anticipated production in each 

program area for each Program Option for the Proposed 

Program analysis. In addition, there are two sets of scenarios 

for the Programmatic EIS. 

Single Lease Sale case – E&D scenario is based on anticipated 

production and activity based on a “typical” sale in each 

program area for which multiple sales are proposed. 

Cumulative case – E&D scenario is based on future activities 

resulting from all lease sales, including past sales, sales in the 

current National OCS Program, and all future sales. 

Proposed Final Program Similar to the Proposed Program phase, E&D scenarios are 

based on anticipated production in each program area for each 

of the Program Options included for the PFP analysis. 

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USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

5.3 NET SOCIAL VALUE 

The NSV analysis is one of several analyses employed by the Secretary in considering the 

Section 18 factors. The NSV analysis provides the Secretary with a quantitative ranking of planning 

areas based on resources and the economic, environmental, and social costs required to extract those 

resources. The analysis looks at the NSV associated with the resources in each planning area by 

computing the benefits less private, social, and environmental costs of extracting these resources. This 

quantitative ranking compares planning areas and assumes the ultimate recovery of all UERR estimated to 

be available as of July 2019, as shown in Table 5-1. For the purpose of this ranking, the NSV analysis 

presented here assumes that all UERR currently unleased will be leased during the initial year of the 

National OCS Program (2019) and then explored, developed, and produced. As noted in Figure 5-8, this 

differs from future stages of National OCS Program analysis when BOEM considers only production 

anticipated to be leased in the proposed lease sales. While society continues to receive the benefits and 

associated costs from previously leased OCS resources, policies relating to their treatment are not subject 

to this DPP decision. Hence, the benefits and costs derived from these previously leased resources are not 

included in this analysis. 

The NSV analysis for the DPP is presented without pre-supposing any decision on the size, timing, and 

location of lease sales. Accordingly, the NSV is an appraisal of each planning area’s value after 

considering the resources and the costs associated with extracting those resources. This information is 

used in preparation for the Secretary’s initial decision on size, timing, and location of lease sales for the 

2019–2024 Program. The results of the NSV analysis, included in Sections 5.3.3 and 5.3.4, are presented 

in the form of a ranking of planning areas by NSV. 

All 26 OCS planning areas are included in the DPP analysis of hydrocarbon and economic potential, but 

4 of the planning areas are estimated to have negligible resources and 7 others to have negligible 

development potential. Therefore, NSV is only calculated for the remaining 15 planning areas, all of 

which have more than 100 million BOE at the inflation-adjusted price-pairing of $100/bbl oil and 

$5.34/mcf of natural gas. 

The three-step NSV calculation is fully explained in Appendix B. Results of the NSV analysis are shown 

at three distinct price levels, discounted at a rate of 3 percent, representing the estimated available 

resources at those price levels. The three price levels are designed to provide planning area-specific 

information to the Secretary of the value of OCS resources under three different sets of energy market 

conditions. 

The first stage (shown as calculation number 1 in Figure 5-12) of the NSV analysis calculates potential 

gross revenues by multiplying the unleased UERR associated with each price level by the applicable oil 

and gas prices related to the specific price level. The second stage (shown as calculation number 2 in 

Figure 5-12) in the calculation subtracts the private costs of exploration, development, production, and 

transportation of the UERR from gross revenues to find the NEV. The third stage (shown as calculation 

number 3 in Figure 5-12) in the analysis subtracts the external costs from the NEV. The external costs are 

the environmental and social costs that companies do not generally pay for but are still associated with the 

exploration, development, production, and transportation of resources from the OCS, as described in 

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USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Section 5.3.2. The resulting value is the NSV. Each component of the NSV analysis is briefly described 

below along with a ranking of planning areas at each stage under the $100/bbl oil price case. 

Figure 5-12: Components of the DPP Net Social Value Analysis 

5.3.1 Net Economic Value Calculation 

The NEV is the private value to society derived from developing hydrocarbon resources found in the 

OCS. The NEV equals the discounted gross revenues from the produced oil and natural gas minus the 

costs required to realize the economic value of the resources. These costs include the discounted costs of 

exploring, developing, producing, and transporting the oil and natural gas to the market. The NEV can be 

considered as the present value of the expected economic rent for all available unleased UERR. A portion 

of the NEV goes to the U.S. government, as lessor, in the form of bonus bids, rents, royalties, and taxes. 

The lessees, as private firms, retain the remainder of NEV as economic profits that can be distributed to 

shareholders around the country.20 

Figure 5-13 shows the range of estimated NEV for each of the 15 planning areas between the $40/bbl oil 

and $160/bbl oil price cases. The areas are ranked based on NEV under the $100/bbl oil price case, 

which is indicated in the figure with the orange line. 

The NEV ranking of planning areas is slightly different than the resource rankings presented in Table 5-1. 

For example, the Chukchi Sea and Beaufort Sea planning areas rank second and fourth in total resources, 

but drop to third and ninth in the ranking of NEV, respectively. Considerable operational challenges 

drive higher operating costs in the Arctic, which generate a lower NEV per BOE produced. In contrast, 

mature areas like the GOM generally have lower operating costs, and thus generate a higher NEV. 

20 Appendix B discusses the 0.95 factor applied to the NEV to account for profits going to foreign shareholders. This adjustment 

to NEV means that what remains, and what is taken into account in this DPP analysis, is only the domestic value. 

Valuation of Planning Areas 5-17 January 2018 
 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Figure 5-13: Net Economic Value Ranges by Planning Area (Ranked by $100/bbl Oil Price Case) 

$ billions 

$0 $250 $500 $750 $1,000 $1,250 $1,500 $1,750 

Central GOM 

Western GOM 

Chukchi Sea 

Eastern GOM 

Southern California 

North Atlantic 

Mid-Atlantic 

Central California 

Beaufort Sea 

Northern California 

Cook Inlet 

North Aleutian Basin 

Gulf of Alaska 

Washington/Oregon 

South Atlantic 

█ Price Case Range 

| $100/bbl Oil Price Case 

Green bars show the range of estimated 

NEV between the $40/bbl and $160/bbl 

price cases in each planning area. The 

highlighted $100/bbl case is used as the 

ranking factor. 

Notes: Estimated NEV is provided as a range from the $40/bbl oil price case to the $160/bbl oil price case. The $100/bbl oil 

price case is represented in between by the orange line. Each of these price cases assumes an inflation-adjusted price for oil and 

for natural gas. St. George Basin, Kodiak, Navarin Basin, Hope Basin, Shumagin, and Norton Basin planning areas in Alaska 

and the Straits of Florida Planning Area are excluded from this figure because they have an estimated negligible development 

value. Aleutian Arc, Aleutian Basin, Bowers Basin, and the St. Matthew-Hall planning areas are excluded from this figure 

because they are estimated to contain only negligible resources. The Gulf of Alaska, Chukchi Sea, and South Atlantic planning 

areas have negligible developmental value at $40/bbl oil price case and are not modeled; instead, they are shown as 0 at the 

$40/bbl oil price case. All values are discounted at a real discount rate of 3 percent. 

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Similar to the resource-to-price relationship, the NEV-to-price relationship is not linear. While costs do 

rise as prices increase, higher prices prompt companies to pursue resources that are more difficult and 

more expensive to develop and produce. If prices advance toward the levels of the $160/bbl oil price 

case, they will allow for a mix of lower-cost and higher-cost fields to be developed at the same time. 

Conversely, if prices settle near or below the $40/bbl oil price case, as they did in late 2015 into 2016, 

companies will focus more of their efforts on the most profitable projects. Given the differences in 

resources and costs under the different price cases, the estimates of NEV for each area and price case are 

provided in the first three columns of Table 5-3. 

While the NEV analysis treats the private expenditures from exploration, development, production, and 

transportation as costs, this spending can be considered a benefit in a broader macroeconomic context. 

For example, the use of labor and capital to search for and extract oil and gas resources contributes to the 

national income. Also, this spending generates regional economic impacts and multiplier effects that 

arise from factors such as the creation of jobs and investment in infrastructure. Additional benefits of 

OCS production are addressed in Appendix B under the discussion of non-monetized benefits. 

5.3.2 Environmental and Social Costs Calculation 

Beyond the private costs used to calculate the NEV, society incurs environmental and social costs from 

the activities and facilities associated with OCS oil and natural gas exploration and development. These 

can include, but are not limited to, impacts on air quality, water quality, commercial fisheries, and beach 

recreation. BOEM uses its in-house Offshore Environmental Cost Model (OECM) to calculate the 

environmental and social costs associated with OCS oil and gas activity. The OECM was developed in 

2001, revised substantially in 2012, and underwent minor revisions in 2014.21 It is designed to model the 

impact of typical activities associated with OCS production and oil spills (other than possible catastrophic 

oil spills, which are analyzed separately) occurring on the OCS. The model uses economic inputs, 

resource estimates, and E&D scenarios as the bases for its calculations. Costs are calculated for six 

categories: (1) recreation; (2) air quality; (3) property values; (4) subsistence harvests; (5) commercial 

fishing; and (6) ecological impacts. 

While the model captures a wide range of environmental and social costs, it is not designed to represent 

impacts on unique resources such as threatened or endangered species, nor on cultural values that are not 

reflected in market transactions. These types of impacts are discussed in Chapter 7 and will be discussed 

in more detail in the Programmatic EIS prepared in conjunction with the Proposed Program. Further, 

these impacts could be subject to mitigation measures at later stages in the development process. 

The OECM is also not designed to represent impacts from catastrophic oil spill events. The OECM only 

considers a range of oil spills up to 100,000 barrels. Given the unpredictable nature of catastrophic oil 

spills, including the many factors that determine their severity, efforts to quantify their unexpected costs 

are less meaningful and more uncertain than the other measures considered in the NSV analysis. In 

addition to the difficulty in calculating the cost of the potential impacts of a catastrophic spill, there are 

similar difficulties in calculating the risk. For these reasons, the risk and impact of catastrophic oil spills 

are not considered in the NSV analysis. Catastrophic oil spills are discussed and considered in Chapter 7 

21 A discussion of the OECM is included in the Economic Analysis Methodology paper (BOEM 2016b), as well as Forecasting 

Environmental and Social Externalities Associated with Outer Continental Shelf (OCS) Oil and Gas Development - Volume 1: 

The 2015 Revised Offshore Environmental Cost Model (OECM) (Industrial Economics, Inc. and SC&A, Inc. 2015a). 

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USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

and in the following papers: Economic Inventory of Environmental and Social Resources Potentially 

Impacted by a Catastrophic Discharge Event within OCS Regions (BOEM 2014), Forecasting 

Environmental and Social Externalities Associated with Outer Continental Shelf (OCS) Oil and Gas 

Development – Volume 2: Supplemental Information to the 2015 Revised Offshore Environmental Cost 

Model (OECM) (Industrial Economics and SC&A 2015b), and Economic Analysis Methodology paper 

(BOEM 2016). Additional information related to catastrophic oil spills, including but not limited to 

potential impacts on endangered species, will be analyzed at the Proposed Program and PFP stages in the 

Programmatic EIS. 

Figure 5-14 shows a ranking of the range of environmental and social costs for the three price levels 

based on the environmental and social costs of the $100/bbl oil price case. The environmental and social 

costs for each of the three different price cases are also shown in the middle three columns of Table 5-2 in 

Section 5.3.4. The OECM results for total environmental and social costs originating from OCS activities 

are subtracted from the NEV to calculate the NSV. Additional information about the calculation of the 

environmental and social costs can be found in Appendix B. 

The ranking of the planning areas in terms of environmental and social costs in Figure 5-14 varies from 

their rankings based on UERR resources in Figure 5-9. Notably, the Arctic planning areas (the Beaufort 

Sea and Chukchi Sea planning areas) rank eighth and tenth in total environmental and social costs, but 

rank fourth and second in UERR, respectively. The Mid-Atlantic Planning Area, which ranks seventh in 

UERR, ranks ninth in environmental and social costs. The ranking differences stem from the relative 

environmental and social impact of OCS activities in the different planning areas. For example, 

recreation and air quality impacts are two of the largest monetized components of the OECM and vary 

widely between planning areas. Additionally, an oil spill in the Mid-Atlantic Planning Area could 

threaten recreational activities, but a spill of equal magnitude in the Arctic potentially would not have the 

same effect on activities such as recreational fishing and beach visitation because fewer people participate 

in these activities in the Arctic. As such, the OECM will show a greater reduction in social welfare in the 

Mid-Atlantic Planning Area when compared to the Arctic even though the Arctic would incur other costs 

such as damages to subsistence harvests. 

The OECM contains an air quality model based on the Air Pollution Emission Experiments and Policy 

Analysis Model (now called AP2) that evaluates the onshore damages caused by dispersed criteria 

pollutants emitted offshore. Because the Mid-Atlantic seaboard is more developed and populous than the 

Arctic, air emissions create larger monetized environmental impacts on human health, agriculture, and 

material damage. Also, the model monetizes potential subsistence harvest impacts from those spills 

modeled in the OECM (of less than 100,000 barrels) for Alaska, but not for other regions.22 Additional 

information on the OECM environmental and social cost components and calculations is included in 

Appendix B, as well as the OECM model documentation. 

22 The OECM is limited to subsistence harvests in Alaska planning areas because of the relative importance of subsistence 

harvests in Alaska and the availability of Alaskan subsistence harvest data (Industrial Economics, Inc. et al. 2015). Although 

other OCS regions have some subsistence harvests, data of the type needed for the OECM are not available. BOEM continues to 

review existing information on subsistence harvests in other regions, and if data on the scope and value of these harvests become 

available, BOEM can modify the OECM to incorporate these impacts. Some information on the presence of subsistence harvests 

in the other regions is discussed in the separate report, Forecasting Environmental and Social Externalities Associated with Outer 

Continental Shelf (OCS) Oil and Gas Development – Volume 2: Supplemental Information to the 2015 Revised Offshore 

Environmental Cost Model (OECM) (Industrial Economics, Inc. and SC&A, Inc. 2015b). 

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USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Figure 5-14: Environmental and Social Costs by Planning Area (Ranked by $100/bbl Oil Price Case) 

$ billions 

$0 $5 $10 $15 $20 $25 

Central GOM 

Western GOM 

Central California 

Southern California 

Northern California 

Eastern GOM 

North Aleutian Basin 

Beaufort Sea 

█ Price Case Range 

| $100/bbl Oil Price Case 

Mid-Atlantic 

Chukchi Sea 

North Atlantic 

Washington/Oregon 

South Atlantic 

Cook Inlet 

Gulf of Alaska 

Red bars show the range of estimated 

environmental and social costs between the 

$40/bbl and $160/bbl oil price cases in each 

planning area. The highlighted $100/bbl oil 

price case is used as the ranking factor. 

Notes: The range of estimated environmental and social costs is shown from the $40/bbl oil price case to the $160/bbl oil price 

case. The $100/bbl oil price case is represented in between by the orange line. Each of these price cases assumes an inflationadjusted price for oil and for natural gas. St. George Basin, Kodiak, Navarin Basin, Hope Basin, Shumagin, and Norton Basin 

planning areas in Alaska and the Straits of Florida Planning Area are excluded from this figure because they have an estimated 

negligible development value. Aleutian Arc, Aleutian Basin, Bowers Basin, and the St. Matthew-Hall planning areas in Alaska 

are excluded from this figure because they are estimated to contain only negligible resources. The Gulf of Alaska, Chukchi Sea, 

and South Atlantic planning areas have negligible developmental value at $40/bbl and are not modeled; instead, they are shown 

as 0 at the $40/bbl oil price level. All values are discounted at a real discount rate of 3 percent. 

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USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

The NSV does not include cost estimates for greenhouse gas (GHG) emissions. However, Appendix B 

shows the consideration of the GHG emissions from upstream activities (i.e., emissions associated with 

the initial exploration, production, and transport of OCS oil and gas resources). Those interested in GHG 

estimates for the full lifecycle of OCS oil and gas can refer to the report entitled OCS Oil and Natural 

Gas: Potential Lifecycle Greenhouse Gas Emissions and Social Cost of Carbon (Wolvovsky and 

Anderson 2016). 

There is an important difference between the environmental social cost calculation done for the DPP 

analyses and that which is done for the subsequent phases of National OCS Program development 

(i.e., Proposed Program and PFP analyses). The DPP only considers the environmental and social costs 

of extracting OCS resources, while the Proposed Program and PFP consider those costs less the relevant 

environmental and social costs from calculated energy market substitutes, resulting in an estimate of the 

incremental environmental and social costs. Incremental environmental and social costs are the 

environmental and social costs from the anticipated activities generated from leases in this National OCS 

Program minus the environmental and social costs from the most likely energy market substitutions 

replacing OCS production in the event that no leasing occurs under an approved National OCS Program. 

Only the incremental environmental and social costs are included because some environmental and social 

costs would occur regardless of whether the 2019–2024 Program was approved. In the absence of OCS 

production, substitute energy sources, which have their own environmental and social costs, would be 

needed to fulfill U.S. demand. This “incremental” analysis is conducted for the Proposed Program and 

PFP analyses when anticipated production stemming from this National OCS Program is analyzed. 

As stated above, the scope of analysis in the DPP is inherently different than in later National OCS 

Program development stages. The DPP analysis estimates the value of the resources less the private and 

social costs of extraction. This analysis considers the large volumes of all available UERR with no 

leasing or market constraints such as rig or worker availability, and defers until later development stages 

the assessment of specific planning area proposals and options. At the Proposed Program and PFP stages, 

the analysis shifts to one that considers domestic demand, the supply of other energy resources, including 

imports, and the energy market substitutions that would be required to replace OCS production in the 

absence of lease sales under an approved National OCS Program. This analysis at later stages includes 

the substitutions analysis and calculation of net environmental and social costs for a subset of all available 

UERR (anticipated production). 

5.3.3 Net Social Value Calculation 

The final result at this National OCS Program stage, the NSV, is the NEV less the present value of 

environmental and social costs anticipated from the planning area. The range of NSV is shown in 

Figure 5-15, ranked under the $100/bbl oil price case from largest to smallest. The entire NSV analysis is 

described in more detail in Appendix B, which also includes a discussion of relevant costs and benefits 

that are not monetized in the DPP analysis. Some of the other costs and benefits do not lend themselves 

easily to quantification and monetization, whereas others are more appropriately estimated in later 

National OCS Program stages. 

Valuation of Planning Areas 5-22 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Figure 5-15: Net Social Value Ranges by Planning Area (Ranked by $100/bbl Oil Price Case) 

$ billions 

$0 $250 $500 $750 $1,000 $1,250 $1,500 $1,750 

Central GOM 

Western GOM 

Chukchi Sea 

Eastern GOM 

Southern California 

North Atlantic 

Mid-Atlantic 

Central California 

Beaufort Sea 

Northern California 

Cook Inlet 

Gulf of Alaska 

North Aleutian Basin 

Washington/Oregon 

South Atlantic 

█ Price Case Range 

| $100/bbl oil Price Case 

Green bars show the range of estimated 

NSV between the $40/bbl and $160/bbl oil 

price cases in each planning area. The 

highlighted $100/bbl oil price case is used 

as the ranking factor. 

Notes: Estimated NSV is provided as a range from the $40/bbl oil price case to the $160/bbl oil price case. The $100/bbl oil 

price case is represented in between by the orange line. Each of these price cases assumes an inflation-adjusted price for oil and 

for natural gas. St. George Basin, Kodiak, Navarin Basin, Hope Basin, Shumagin, and Norton Basin planning areas in Alaska 

and the Straits of Florida Planning Area are excluded from this figure because they have an estimated negligible development 

value. Aleutian Arc, Aleutian Basin, Bowers Basin, and the St. Matthew-Hall planning areas are excluded from this figure 

because they are estimated to contain only negligible resources. The Gulf of Alaska, Chukchi Sea, and South Atlantic planning 

areas have negligible developmental value at $40/bbl oil price case and are not modeled; instead, they are shown as 0 at the 

$40/bbl oil price case. All values are discounted at a real discount rate of 3 percent. 

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USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

In addition to the inclusion of incremental environmental and social costs, the NSV analysis is expanded 

for the Proposed Program and PFP analyses to include domestic consumer surplus. Domestic consumer 

surplus measures the additional benefits that U.S. consumers receive from the slight energy market price 

decreases that occur through the production of OCS resources. Calculating consumer surplus is not 

applicable at the DPP stage since BOEM’s consideration of all available resources would skew the results 

when combined with other real-world energy market information and forecasts. More information on the 

treatment of incremental environmental and social costs and consumer surplus in later National OCS 

Program stages can be found in the Economic Analysis Methodology paper for the 2017–2022 Program 

(BOEM 2016b). A new paper will be prepared for the Proposed Program and PFP analyses. 

5.3.1 Results and Conclusion 

Detailed measures of the NEV, environmental and social costs, and NSV for each planning area are 

shown in Table 5-3. Planning areas are ranked by the NSV of the $100/bbl oil price case. The first three 

columns show the NEV per planning area, second three columns show the environmental and social costs, 

and the final three columns show the results of the NSV calculation (NEV less environmental and social 

costs). The three different price cases show what the estimated benefits and costs would be under three 

vastly different energy market conditions. However, these estimates are rooted in uncertainty at many 

levels beyond just price. In addition to the price uncertainty, there is also resource uncertainty, extraction 

cost uncertainty, environmental and social cost uncertainty, and others. Actual values different from 

those used in the NSV analysis can greatly affect the NSV. The nature of these uncertainties is discussed 

in Chapter 10. 

The valuation of planning areas is provided as one metric that the Secretary can use to help evaluate 

multiple Section 18 factors. As this is only part of the information the Secretary considers in making a 

decision, simply because a planning area ranks high, or low, does not determine its inclusion or exclusion 

in the National OCS Program. 

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Table 5-3: Ranking of Planning Areas by $100/bbl Oil Price Case Net Social Value for Unleased UERR as of July 2019 

Rank Planning Area 

Net Economic Value 

($ billion) 

Environmental and Social Costs 

($ billion) 

Net Social Value 

($ billion) 

$40/bbl 

$2.14/mcf 

$100/bbl 

$5.34/mcf 

$160/bbl 

$8.54/mcf 

$40/bbl 

$2.14/mcf 

$100/bbl 

$5.34/mcf 

$160/bbl 

$8.54/mcf 

$40/bbl 

$2.14/mcf 

$100/bbl 

$5.34/mcf 

$160/bbl 

$8.54/mcf 

1 Central GOM $137.1 $789.9 $1,571.7 $14.3 $18.8 $21.1 $122.8 $771.1 $1,550.6 

2 Western GOM $27.5 $283.7 $604.2 $10.1 $13.7 $14.8 $17.4 $270.0 $589.3 

3 Chukchi Sea * $121.2 $535.5 * $2.3 $3.1 * $118.9 $532.3 

4 Eastern GOM $16.1 $113.0 $224.4 $2.8 $3.5 $3.8 $13.3 $109.5 $220.6 

5 Southern 

California $5.4 $78.5 $170.5 $2.6 $3.9 $4.6 $2.8 $74.6 $165.9 

6 North Atlantic $11.3 $74.6 $127.4 $1.8 $2.2 $2.3 $9.5 $72.5 $125.1 

7 Mid-Atlantic $11.3 $70.8 $140.8 $2.2 $2.9 $3.2 $9.1 $67.9 $137.6 

8 Central 

California $13.7 $67.2 $127.3 $6.4 $8.4 $9.2 $7.3 $58.8 $118.1 

9 Beaufort Sea $0.0 $54.9 $310.3 $0.5 $3.0 $3.6 -$0.5 $51.9 $306.7 

10 Northern 

California $1.5 $28.3 $61.8 $2.3 $3.8 $4.5 -$0.8 $24.5 $57.3 

11 Cook Inlet $0.0 $16.8 $43.8 $0.1 $0.1 $0.1 -$0.1 $16.6 $43.7 

13 Gulf of Alaska * $14.1 $40.8 * $0.1 $0.2 * $14.0 $40.6 

12 North Aleutian 

Basin $0.2 $14.9 $35.6 $2.0 $3.1 $3.3 -$1.7 $11.8 $32.3 

14 Washington/ 

Oregon $0.7 $6.9 $14.5 $0.2 $0.3 $0.4 $0.5 $6.6 $14.1 

15 South Atlantic * $4.1 $10.9 * $0.2 $0.3 * $3.9 $10.6 

Notes: St. George Basin, Kodiak, Navarin Basin, Hope Basin, Shumagin, and Norton Basin planning areas in Alaska and the Straits of Florida Planning Area are excluded from 

this table because they have only an estimated negligible development value. Aleutian Arc, Aleutian Basin, Bowers Basin, and the St. Matthew-Hall planning areas are excluded 

from this table because they are estimated to contain only negligible resources. All values are discounted at a real discount rate of 3 percent. All price levels represent a constant, 

inflation-adjusted price throughout the life of the National OCS Program. 

* For the Chukchi Sea, Gulf of Alaska, and South Atlantic planning areas, there is negligible developmental value in the $40/bbl oil–$2.14/mcf gas price case. As a result, NSV is 

not calculated for these areas at the $40/bbl oil price case. 

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USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Chapter 6 Planning Area Location Considerations 

Chapter 6 includes a discussion of several different Section 18(a)(2) factors that the Secretary must 

consider when determining the timing and location of lease sales. Specifically, this chapter will focus on 

those factors associated with regional and national energy markets and other uses of the OCS. 

6.1 NATIONAL ENERGY MARKETS 

The following sections discuss national energy markets and the location of OCS planning areas relative to 

the needs of national energy markets, a factor the Secretary must consider under Section 18(a)(2)(C). 

U.S. energy markets are considered in the presence of a persistent, although recently shrinking, gap 

between domestic oil production and consumption; low oil and natural gas prices; continuing concerns 

over the United States’ negative balance of payments in world trade; and increasing domestic onshore 

production. To assist the Secretary in his decisions on the size, timing, and location of lease sales, this 

chapter includes an analysis of the markets for crude oil, natural gas, and refined petroleum products.23 

6.1.1 Recent Developments in Oil Markets 

Oil markets change frequently, but have recently been affected by a few defining characteristics. First, 

onshore production in the United States has grown rapidly. This has caused ripple effects throughout 

national and global oil markets, leading in part to a second fundamental change in oil markets, low, and 

relatively stable, prices. A third, more recent change is the elimination of oil export limitations in the 

United States. This change has had a smaller impact on the oil markets, but is still notable. 

Over the past decade, the United States has experienced a significant increase in oil and natural gas 

production from shale and other tight formations. This development has resulted in a significant decline 

in U.S. dependence on imported crude oil (EIA 2017a). EIA forecasts that U.S. crude oil production will 

increase in 2017 and that the current record, set in 1970, will be surpassed in 2018 (EIA 2017b). The 

greatest near-term U.S. production growth is expected to come from the Permian region in Texas and 

from the OCS. 

The low oil prices, which began in late 2014, have been a major characteristic of recent oil markets. 

These low oil prices have affected offshore and onshore production in different ways, given a different 

level of price sensitivity between the two production sources. Onshore production, specifically from tight 

formations, is a more price-responsive source of supply than OCS production, given the short time 

required to drill and complete tight oil wells and the fact that planned or existing projects can be ramped 

up or down relatively quickly (EIA 2016a). Alternatively, OCS projects can take 10 years or more from 

lease award to initial production, and are, therefore, subject to general long-term price expectations rather 

than short-term price swings. While still affected by the low-price environment, OCS projects generally 

provide a steady and more predictable source of oil and gas for long periods once production begins. This 

23 Petroleum products are the output of refineries and made from crude oil (e.g., gasoline, diesel fuel, jet fuel, kerosene). The 

OCS Lands Act focuses on crude oil and natural gas; nevertheless, petroleum, or “refined” products are included in this analysis 

primarily because they represent the form in which end users consume oil that, in its crude form, is used only by refineries. 

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USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

effect is apparent as OCS oil production is expected to increase in 2017 and again in 2018 mostly from 

projects sanctioned prior to 2014 (EIA 2017c). 

Another change in oil markets is the December 2015 legislative change eliminating the decades-old oil 

export limitations. The recent removal of export restrictions will impact net imports, but the actual degree 

of that impact is largely unknown due to the influence of other market factors. Since the elimination of 

the export restrictions, U.S. crude oil has been exported to the Caribbean, Latin America, Europe, and 

Asia (EIA 2017d). BOEM continues to study the change to oil markets in response to the elimination of 

the oil export limitations. 

With increased domestic production, both net and gross imports of crude oil have been declining, 

reducing U.S. dependence on imported petroleum. However, net imports of crude oil are expected to 

remain above zero throughout the period (2016–2050) covered by EIA’s AEO 2017 (EIA 2017e). A 

recent EIA report (EIA 2015a) showed that the elimination of the oil export limitations would result in 

only a very low rate of decline in net imports through 2025, the last year of projections. An additional 

factor that could affect net imports is the adjustment of the domestic industry to current low prices. If 

prices remain lower than anticipated, it could provide both downward pressure on domestic production 

and upward pressure on demand, leading to higher imports. Additional information on oil imports and 

exports is included in the next section. 

6.1.2 Relevant Developments in Domestic Petroleum Markets 

Petroleum refineries are the primary market for crude oil, which generally is not consumed in its raw 

state. Refineries use crude oil as feedstock to create an array of petroleum products shipped to various 

markets around the country and the world. The refined petroleum products market changed significantly 

over the past several years as the abundance of domestic oil production changed the supply and 

consumption patterns in domestic crude oil markets. 

Onshore tight oil has returned the United States to the position it once held as the top oil and petroleum 

liquids producer in the world. As mentioned above, the recent increase in domestic oil production has 

provided a number of benefits and driven major changes in supply and consumption patterns in domestic 

crude oil markets. One major change in the domestic oil markets is that the vast majority of the oil 

produced from tight formations is light, sweet crude, in contrast to the heavier sour crudes that generally 

come from both other domestic production, including offshore, and imported sources. In fact, roughly 

90 percent of the nearly 3 million-barrel-per-day growth in U.S. production from 2011 to 2014 consisted 

of light, sweet grades, which are higher-quality crudes than the medium-to-heavy sour crude traditionally 

found on the OCS (EIA 2015b). As a result, many domestic refineries spent tens of billions of dollars 

retooling or expanding their medium/heavy refinery facilities to handle the increased quantities of 

domestic light crude (Auers and Couture 2015). 

This phenomenon has reduced the overall need for imported oil, and, beginning in 2011, U.S. exports of 

refined petroleum products have exceeded imports. However, these overall numbers mask a dramatic 

change in the composition of remaining imports. Figure 6-1 shows the extent to which huge quantities of 

domestic light crude oil have replaced light crude imports. As shown in the graph, in 2009, light crude 

imports accounted for more than 20 percent of all imports. However, given the recent increase in 

domestic light crude production, light crude imports have fallen to approximately 11 percent of all 

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imports. The decline in medium and heavy crude imports has been much smaller, with heavy crudes now 

making up more than half of all imports. While it is possible the trend of increased onshore production 

and reduced domestic consumption will continue to reduce the need for imported oil overall, the volume 

of heavy and medium crude imports indicate there is still a need for the medium-to-heavy crudes found 

on the OCS.24 

Figure 6-1: U.S. Crude Oil Imports by Grade 

Source: EIA 2017f 

6.1.3 Relevant Developments in Domestic Natural Gas Markets 

The surge in the use of new technology to develop large onshore tight-formation plays initially focused on 

natural gas. This early success led to significant downward pressure on gas prices, to the point that 

producers began to target projects that yielded the more valuable liquids in association with natural gas. 

Nevertheless, plentiful domestic natural gas production has kept domestic natural gas prices below 

benchmark prices in other parts of the world. Companies are constructing permitted liquefied natural gas 

export terminals, hoping to take advantage of world prices that can be more than twice the level of 

U.S. prices. 

Less expensive natural gas has reduced manufacturing energy and feedstock costs and has enabled 

manufacturing companies to increase U.S. operations or return manufacturing from overseas. Natural gas 

directly powers many large manufacturing facilities and most refineries. Natural gas feedstock is also 

used for non-fuel products such as fertilizer and plastics. This natural gas renaissance is helping to stem 

24 Markets for crude oil and refined petroleum products should not be confused. The focus of the OCS Lands Act is on crude oil 

and natural gas; therefore, the focus of this discussion of oil markets and refineries generally is on the demand for, and 

availability of, crude oil as an input, and the discussion does not include extensive information on refined products. 

Planning Area Location Considerations 6-3 January 2018 
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Planning Area Location Considerations 6-4 January 2018

the long-term decline in U.S. manufacturing jobs and helping to provide a competitive advantage for the 

U.S. manufacturing industry (Motavalli 2012). 

6.1.4 Oil and Natural Gas Consumption and Production Estimates

EIA’s reference case analysis projects that the United States will continue to heavily rely on oil and 

natural gas to meet its energy needs under current laws and regulations. In 2016, 65 percent of energy 

consumed in the United States came from petroleum/other liquids and natural gas; the EIA forecasts that 

this percentage will increase through 2050, based on current laws and regulations. Figure 6-2 shows total 

U.S. energy consumption by fuel source from 1950 to 2016 and includes the EIA’s AEO 2017 projections 

from 2017 through 2050. The projections shown in Figure 6-2 indicate that the share of energy obtained 

from oil will remain roughly consistent, whereas domestic natural gas consumption is expected to grow 

through 2050. The projections shown in Figure 6-2 are from the EIA’s AEO 2017 reference case, which 

includes current laws and regulations as of the development of the outlook. 

Figure 6-2: Historical and Forecasted U.S. Energy Consumption by Fuel Type

Source: EIA 2017e, EIA 2017g

Oil and gas production in the United States has increased rapidly in recent years. As shown in Figure 1-4, 

OCS oil production as a percent of total oil production peaked in 2009 at 30 percent of domestic 

production, but the OCS’s relative contribution has fallen in recent years, due to increases in onshore 

production. The OCS contribution to domestic natural gas production peaked at 27 percent in 1990, but 

has fallen drastically given both declines in OCS natural gas production and increases in onshore 

domestic production. The EIA projections show OCS natural gas production will continue to provide a 

minimal contribution to domestic natural gas production through 2050. Projections show a short-term 

increase in OCS oil production, but then a decline and relatively stable levels of OCS oil production 

through 2050. Figures 1-4 and 1-5 in Chapter 1 show EIA’s projections of U.S. offshore and onshore oil 

← Historical Forecast →
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

and natural gas production from 2017 through 2050. Again, these projections are based on current laws, 

regulations, and policies and assume resources are not subject to further leasing restrictions.25 

6.1.5 Future Unpredictability and Possible Policy Implications 

Many factors influence actual oil and gas production, prices, and consumption. These factors include 

domestic and foreign GDP growth rates; technology development (affecting the supply and/or demand 

side); geopolitical events; access to oil and gas resources; and laws, regulations, and policies. 

Improvements to existing technology have allowed access to hydrocarbon resources previously deemed 

too expensive or difficult to develop by more traditional means. This renaissance has reversed the 

long-term decline in U.S. oil production, catapulting the United States to the position as the world’s top 

producer of petroleum and natural gas hydrocarbons (EIA 2017h). 

The factors affecting oil and gas prices are complex and often unpredictable. Major changes often take 

many years and can be costly and disruptive if they require elements such as new infrastructure or 

transportation networks. The volatility of U.S. energy needs, oil and gas supply, and changes in prices 

cannot be predicted over the next 40 to 60 years. Markets will adjust to the changes that occur, but 

adjustments can be eased by resource availability. All other things being equal, energy policies that 

maximize, rather than limit, the availability of energy resources increase the ability of markets to respond 

to the challenges of the future. 

In addition to the future unpredictability of markets and prices, future policies outside of those directly 

related to OCS leasing could affect OCS exploration and production. Many countries will consider new 

policies to address GHG emissions, and other national policies could affect either the demand for or 

supply of certain forms of energy. Substantial policy changes could affect U.S. energy markets and the 

contribution of oil and gas to those markets. While the information provided in the present analysis does 

not include speculation about specific future policies, throughout the implementation of the National OCS 

Program, the Secretary has flexibility to re-evaluate the Nation’s energy needs and current market 

developments, and can revise lease sale offerings in accordance with the Section 18 process. Revised 

energy policies could prompt companies to bid on fewer leases, develop fewer projects on those leases, or 

abandon fields sooner, regardless of decisions in this National OCS Program. Changes in energy policies 

will continue to be studied in future analyses with regard to this and future National OCS Programs. 

6.1.6 The Contribution of OCS Oil and Natural Gas 

As discussed earlier, the OCS is a major long-term supplier of reasonably predictable conventional crude 

oil, and, to a lesser extent, natural gas. OCS production is an important part of the President’s 

AmericaFirst Offshore Energy Strategy to promote energy security and economic growth (E.O. 13795). 

All domestic production serves to reduce exposure to the unpredictability of foreign oil sources and 

resulting price volatility. OCS oil production complements onshore oil production, leading to greater 

stability in world markets overall. Broadly defined, the United States now has two general sources of 

domestically produced oil and natural gas supply: relatively quick turn-around, onshore tight oil projects 

that produce higher-quality crude, and longer-term, traditional projects that generally produce medium-toheavy sour crudes. Projects like those on the OCS provide a fairly stable source of oil and gas that is less 

25 EIA projections are based on current laws, regulations, and policies and, therefore, assume that all OCS areas are availbale for 

leasing at the end of the 2017–2022 Program except those that are withdrawn or still under moratoria at that time. 

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susceptible to changes in markets or assumptions including those for undiscovered resources, prices, 

technology, and recovery rates.26 This overall stability allows for longer-term planning for infrastructure 

and other needs. More information on the importance of OCS production is described in the next two 

sections. Also, as described in Section 1.2, in addition to its contribution to energy markets by providing 

oil and gas fuel and refinery feedstock, the National OCS Program provides for significant benefits, 

including billions of dollars of revenues to Federal, state, and local governments, as well as important 

employment benefits. 

6.1.6.1 Ability of OCS Production to Fulfill Short-term Needs 

OCS areas can provide oil and natural gas base load production for decades to come. As described in 

Section 6.1.1, OCS production is not as responsive to price changes as is production from onshore tight 

formations, because a relatively longer time commitment is required for production offshore. However, 

both industry and USDOI are able to more quickly respond to low prices and a reduction in demand for 

OCS oil and gas than high prices and an increase in demand. 

The OCS cannot provide resources to quickly mitigate the effects of a national energy emergency, such as 

a large portion of the world’s oil supply being taken offline. OCS projects take years to develop and even 

then, development can be further delayed by rig unavailability, time required to construct facilities, and 

other factors. 

Similarly, the OCS leasing and development processes are lengthy and make it difficult to quickly make 

available additional undiscovered resources in response to changing energy needs. Should conditions 

warrant the need for energy production from areas not fully analyzed in the National OCS Program 

analyses, absent new legislation, the multi-year process of preparing a new National OCS Program must 

be undertaken, and it would take years before new lease sales could be held and leases awarded. Even if 

an area were fully analyzed during program development, the sale development process is lengthy and 

adds to the time needed to realize new leasing opportunities. Following lease award, it would still take 

many more years before industry could begin production on new projects capable of noticeably increasing 

overall production, even in the Western and Central GOM planning areas. In frontier areas, there would 

be further delays to devise exploration strategies, to obtain and transport needed exploration rigs, and to 

build the infrastructure/facilities needed to support development and production. Thus, when making 

decisions for this National OCS Program, an important consideration is the value of a National OCS 

Program that provides energy markets the option of responding to energy needs in the coming years, or 

even decades into the future. 

Conversely, if the United States’ need for oil and/or gas declines relative to supply, the Secretary can 

respond fairly quickly by cancelling or limiting lease sales and the OCS industry can also respond quickly 

by bidding on fewer leases or delaying development (within the limits of the primary term of the lease). 

Operators can also decide to postpone or abandon plans to explore, develop, or produce on leased blocks. 

For example, recent GOM Region bidding and exploration activity has declined in response to relatively 

low oil and natural gas prices. The decline in bidding activity is greatest on the mature GOM shelf, which 

is predominantly a natural gas province. 

26 Many of the resource estimates for tight oil are necessarily tentative, given the associated data availability and unforeseen 

technological/efficiency advances. 

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6.1.6.2 Importance of OCS Production 

Although overall net petroleum import levels have been decreasing, OCS production is still important to 

U.S. energy markets. Not all oil is equal—the medium-to-heavy sour crudes produced from the OCS are 

still needed in U.S. refineries. This is partly because much of GOM refinery capacity remains equipped 

for medium and heavy crude rather than the light, sweet crude being produced in such abundance in 

recent years. 

New production from the OCS would help meet the United States’ continued energy demand and 

maintain a diversity of supply. Diversity of supply mitigates the effects of import disruptions and 

cushions the consequences of other disruptive forces. Volatile energy prices and continued dependence 

on foreign energy, especially for crude oil, raise important energy policy issues about energy supply 

options and their effects on the economy and the environment. The recent increase in domestic oil 

production, when added to OCS and existing onshore production, has helped to increase world oil supply. 

The larger base of world supply has created greater price stability, because supply disruptions of a given 

volume no longer cause the same percentage change in overall supply. Increases and decreases in 

U.S. production affect the world market for oil, influencing prices, and the flexibility of the United States 

to respond to international problems. This relationship could become even more direct with the recent 

lifting of oil export restrictions. Any significant declines in OCS oil production therefore would prevent 

the United States from fully enjoying the benefits of the U.S. fracking boom. 

6.2 REGIONAL ENERGY MARKETS AND THE LOCATION OF OCS REGIONS 

In making the decisions on size, timing, and location of OCS oil and gas leasing for the National OCS 

Program, the Secretary must consider “...the location of [OCS] regions with respect to, and the relative 

needs of, regional and national energy markets” (Section 18(a)(2)(C) of the OCS Lands Act). The 

following “regional energy considerations” discussion provides information on the immediate markets for 

crude oil and natural gas as well as overall energy production and consumption. To analyze energy 

markets regionally, BOEM uses Petroleum Administration for Defense Districts (PADDs) from the EIA 

to group all 50 states by 5 separate districts.27 The PADDs, shown in Figure 6-3, allow users, including 

BOEM, to analyze regional movements of natural gas and petroleum. 

27 Alaska is separated from other states in the West Coast PADD in Figure 6-4 through 6-7 because it has its own OCS region, 

and because its large oil production and low consumption masks a very different production-consumption relationship than is 

found in other states. Based on data availability, Alaska is grouped with the remaining West Coast PADD states for the other 

tables and figures. 

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Figure 6-3: Petroleum Administration Defense Districts 

Source: EIA 2016 

6.2.1 Regional Production and Consumption 

Regional energy markets are defined by the amount of crude production, refining, and consumption that 

occurs in each region. Figures 6-4 and 6-6 show proportional petroleum production and consumption by 

region in the United States in 2016. Figures 6-5 and 6-7 similarly show production and consumption by 

PADD for natural gas. To show the differences between Alaska and the rest of the West Coast PADD, 

Alaska is shown separately in Figures 6-4 through 6-7. One noticeable theme is that the Gulf Coast 

PADD, which includes the GOM OCS, is responsible for a majority of both domestic oil and natural gas 

production, but consumes a much smaller share. The East and West Coasts and Midwest PADDs 

consume close to 70 percent of the domestic oil and natural gas used in the United States, but supply only 

about 26 percent of domestic oil and 34 percent of natural gas production. As shown in Chapter 5, the 

coastal PADDs all have significant OCS resources that could be used to meet regional energy needs. 

Planning Area Location Considerations 6-8 January 2018 
 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Figure 6-4: Contribution to Oil Production by Figure 6-5: Oil Consumption by PADD 

PADD 

Gulf 

Coast 

62% 

Mid-West 

19% 

Rocky 

Mountain 

7% 

Alaska 

6% 

East Coast 

< 1% 

East Coast 

29% 

Gulf 

Coast 

27% 

Mid-West 

25% 

West 

Coast 

15% 

Rocky 

Mountain, 

3% Alaska 

1% 

West 

Coast 

6% 

Source: EIA 2017i Source: EIA 2017j 

Figure 6-6: Contribution to Marketed Natural Figure 6-7: Natural Gas Consumption by PADD 

Gas Production by PADD 

Gulf 

Coast 

48% 

East Coast 

19% 

Alaska 

9% 

West 

Coast 

1% 

Mid-West 

14% 

Rocky 

Mountain 

13% 

East Coast 

30% 

Gulf 

Coast 

27% 

Mid-West 

25% 

West 

Coast 

13% 

Rocky 

Alaska Mountain, 

1% 4% 

Source: EIA 2017k Source: EIA 2017j 

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6.2.2 Regional Transportation 

While clearly there are differences between the production and consumption levels of every PADD, 

resources must be transported between regions to ensure that each PADD is able to meet its consumption 

needs. Because crude oil and natural gas are rarely suitable for consumption without going through a 

refining/processing stage during which various final products are extracted, refineries and gas-processing 

facilities are the primary markets for oil and gas. Oil and natural gas are fungible resources, even more so 

once refined and processed, making location less relevant at later stages. Therefore, refinery capacity 

within a region is a key component of each region’s ability to support its own demand or the national 

energy demand. Figure 6-8 shows the percent of U.S. refining capacity in each PADD. 

Even though the East Coast accounts for 29 percent of total U.S. oil consumption, it only contains 

7 percent of the United States’ refining capacity. To fulfill the regional energy demand, a network of 

pipelines, trains, trucks, and barges is required to transport resources to refineries and then again to the 

final consumer. 

Each of the PADD regions receives crude oil and petroleum products in three different ways: production, 

regional imports, and foreign imports. Similarly, most of the regions have at least some regional and 

foreign exports. Figure 6-9 shows the crude oil and petroleum production and movement by pipeline, 

tanker, barge, and rail for each PADD region. The Gulf Coast PADD has the most throughput of oil and 

petroleum products because it has the largest production and refining capacity and receives the largest 

amount of foreign imports. The Gulf Coast PADD provides to consumers the largest share of both 

foreign and regional exports. 

Figure 6-8: U.S. Refining Capacity by PADD, 2016 

Gulf Coast 

52% 

Mid-West 

21% 

West Coast 

16% 

East Coast 

7% Rocky Mountain 

4% 

Source: EIA 2017l 

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Figure 6-9: U.S. Crude Oil and Petroleum Production and Import/Export by Region, 2016 

-4,000 

-2,000 

0 

2,000 

4,000 

6,000 

8,000 

Million Barrels

█ Regional Imports 

█ Foreign Imports 

█ Production 

█ Foreign Exports 

█ Regional Exports 

East Coast Midwest Gulf Coast Rocky West Coast 

Mountains 

Note: This reflects crude oil and petroleum production and movement by pipeline, tanker, barge, and rail for each PADD region. 

Sources: EIA 2017m, EIA 2017n, EIA 2017o 

Examining in particular the regional movement, Table 6-1 shows the 2016 inter-PADD movement of 

petroleum products by tanker, pipeline, barge, and rail.28 Table 6-2 shows the 2016 inter-PADD 

movements of crude oil. Approximately 60 percent of the petroleum product movements by tanker, 

pipeline, barge, and rail originated in the Gulf Coast PADD, which, again, includes the GOM OCS. 

Approximately 80 percent of these shipments from the Gulf Coast PADD went to the East Coast PADD. 

Table 6-1: 2016 Petroleum Product Shipments by Tanker, Pipeline, Barge and Rail (million barrels) 

PADD From 

PADD 1 

From 

PADD 2 

From 

PADD 3 

From 

PADD 4 

From 

PADD 5 Total Receipts 

To PADD 1 

(East Coast) N/A 168 1,168 0 0 1,336 

To PADD 2 

(Mid-West) 164 N/A 261 86 0 512 

To PADD 3 

(Gulf Coast) 5 350 N/A 84 0 439 

To PADD 4 

(Rocky Mountain) 0 80 0 N/A 0 81 

To PADD 5 

(West Coast) 0 55 68 25 N/A 147 

Total Shipments 169 653 1,497 195 0 2,514 

Source: EIA 2017n 

28 EIA does not track transport of petroleum products by truck. 

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Table 6-2: 2016 Crude Oil Shipments by Tanker, Pipeline, Barge and Rail (million barrels) 

PADD From 

PADD 1 

From 

PADD 2 

From 

PADD 3 

From 

PADD 4 

From 

PADD 5 

Total 

Receipts 

To PADD 1 

(East Coast) N/A 65 13 1 0 78 

To PADD 2 

(Mid-West) 2 N/A 291 201 0 493 

To PADD 3 

(Gulf Coast) 1 371 N/A 18 0 391 

To PADD 4 

(Rocky Mountain) 0 86 0 N/A 0 86 

To PADD 5 

(West Coast) 0 49 1 0 N/A 49 

Total Shipments 3 571 304 220 0 1,098 

Source: EIA 2017o 

While Tables 6-1and 6-2 show the inter-PADD movements, the United States exports additional 

petroleum products internationally, as shown in Figure 6-9. In some instances, it makes more economic 

sense to export refined petroleum products to other countries than to transfer them between regions. For 

example, most of the U.S. refined petroleum product exports come from the Gulf Coast due to a decline 

in U.S. demand for gasoline and an increase in refinery capacity. Gulf Coast refineries have a 

competitive international advantage because they use the lower quality, cheaper crude; run on natural gas 

(which is inexpensive in the United States); and are close to the emerging Latin American markets 

(EIA 2012a). Because of these advantages, pipeline capacity, and other regulatory issues (including 

Section 27 of the Merchant Marine Act29 [P.L. 66-261, 46 U.S.C. 883]), refineries in the Gulf Coast often 

export gasoline to Latin America rather than shipping it to the East Coast. The East Coast receives 

refined product imports from European refineries, which face stronger relative demand for diesel fuel 

than for gasoline. The Midwest, with its expanded production, is now much less dependent on Gulf Coast 

refined products (EIA 2012a). Although data are not currently available, energy markets are becoming 

increasingly global now that U.S. limitations on crude oil exports have been removed. BOEM is 

continuing to analyze how this change will affect domestic and regional energy markets. 

Given the interconnectedness of national and international markets, domestically produced fuel has a 

direct impact on U.S. energy markets, even if it is consumed abroad. BOEM does not track what portion 

of OCS-derived fuels is consumed domestically, but instead considers the impact of OCS production on 

national and international markets. This approach was upheld in Center for Sustainable 

Economy v. Department of the Interior, 779 F.3d 588 (D.C. Circuit 2015). The court found that “what 

matters in determining whether OCS-derived fuel meets national needs is not whether the additional OCS 

fuel is consumed domestically, but whether it helps to satisfy domestic needs for fuel security and net 

supply, both in aggregate and over time.” 

6.2.3 Regional Energy Prices 

Regional production-consumption gaps, proximity to production areas, and existing transportation 

constraints can affect regional prices for petroleum and natural gas products. For gasoline prices, the 

29 The Merchant Marine Act requires that all goods transported by water between U.S. ports be carried on U.S. flagships, 

constructed in the United States, owned by U.S. citizens, and crewed by U.S. citizens and U.S. permanent residents. 

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largest factor affecting prices is the cost of crude oil. The EIA estimates that in 2016, approximately 

45 percent of the price of a gallon of gasoline was the cost of crude oil, 21 percent was from Federal and 

state taxes, 18 percent was from refining costs and profits, and 16 percent was distribution and marketing 

(EIA 2017p). Regionally, gasoline prices can vary based on taxes from both the state and local 

governments. Another regional factor affecting price is the costs and profits of refineries. Because the 

crude oil inputs vary by region and the gasoline characteristics of the output30 are also different by region, 

price can vary greatly. After refining, gasoline is usually shipped from the refinery by pipeline to 

terminals and then distributed to gasoline stations by tanker truck. Thus, the distance from refinery to 

consumption point can greatly affect the final cost (EIA 2017p). 

6.2.4 Alaska Regional Energy Markets 

As shown previously in Table 5-1, the Alaska planning areas as a whole appear to have huge, if uncertain, 

oil and gas resource endowments. Arctic areas (Beaufort Sea and Chukchi Sea) have especially 

promising oil and gas potential at higher prices. In particular, Arctic OCS oil could be important to 

Alaska for continued operation of the TAPS. Declining onshore production from Prudhoe Bay is 

affecting the viability of TAPS, which requires a certain level of throughput to operate without posing 

major technological challenges. Depending on circumstances such as timing and oil prices, new OCS 

production could help provide the additional throughput needed to extend the life of TAPS, allowing it to 

continue to carry oil from northern Alaska for many years in the future (NETL 2014). The State of 

Alaska and others raised the issue of the long-term viability of the TAPS pipeline and the role that OCS 

production could play in extending its life in comments on the development of this National OCS 

Program. 

Many Alaska OCS areas have the potential to contribute significantly to U.S. energy needs in the future; 

however, more exploration is required, and additional infrastructure would be needed before major new 

production could begin. Outside of Cook Inlet, which is close to commercial markets as well as to 

infrastructure that accommodates activities on state leases, the Alaska OCS is fairly remote. 

In the remaining planning areas, significant new infrastructure investments would be required. In the 

Chukchi Sea, infrastructure construction would be necessary to produce and transport hydrocarbon 

resources to TAPS. In the Beaufort Sea, an existing network of onshore and nearshore infrastructure 

based out of Prudhoe Bay serves to improve the economic viability of OCS development relative to the 

Chukchi Sea. Similarly, the Gulf of Alaska and North Aleutian Basin planning areas would require 

pipeline and infrastructure development to connect these areas to potential markets. The remaining 

Alaska planning areas are not anticipated to have significant development potential and would likely not 

support the production of oil and gas to support Alaska or other energy markets. 

6.2.5 Pacific Regional Energy Markets 

West Coast gasoline prices are considerably higher than those in all other PADDs. In particular, 

California gasoline prices are higher than those in any other of the contiguous states. California requires 

gasoline to be “reformulated” to reduce the environmental impact of the burned gasoline. This process 

30 States and some local jurisdictions have responded to air quality requirements with varying standards for gasoline composition, 

creating the need for refineries to modify their output for specific markets. Specific refineries will produce only a subset of the 

gasoline varieties required for different markets. 

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requires a special blend of fuels, which is only produced at a limited number of refineries. In addition, 

California refineries are already running at capacity to meet demand. Because supplies are already 

limited, any disruption in supply can cause prices to spike even higher. Given the large distance between 

the West Coast PADD and the majority of refineries in the Gulf Coast PADD, as well as a lack of 

pipelines crossing the Rocky Mountains, replacement supplies are farther away and can cause the price 

spikes to last longer (EIA 2012b). 

The Pacific OCS has significant oil and natural gas resources (see Table 5-1), which could help meet 

regional energy needs, but the West Coast PADD would need additional refinery capacity to allow the 

region to use those resources. 

6.2.6 Gulf of Mexico Regional Energy Markets 

The GOM Region has by far the greatest ability to use its resource potential to supply oil and gas to the 

United States’ top three consuming PADDs: the East Coast, Gulf Coast, and Midwest. Given the 

different qualities of crude discussed earlier, production from the OCS is very important to U.S. energy 

markets to fulfill the demand at the Gulf Coast refineries for medium/heavy and sour crudes. 

6.2.7 Atlantic Regional Energy Markets 

The East Coast PADD is heavily dependent on foreign imports of crude for its refineries. Although the 

Gulf Coast is a large exporter of gasoline, due to infrastructure constraints and Merchant Marine Act 

restrictions on using non-U.S.-flagged vessels for transport, it is still more efficient for the east coast to 

receive some imports of refined products from Canada and Europe. The imports are especially needed 

during the winter when demand increases and regional imports are insufficient to meet the increases in 

demand (EIA 2014). 

The Atlantic OCS contains significant resources, as shown in Table 5-1. Depending on refinery 

capability, production from OCS areas along the Atlantic coast could potentially feed directly into the 

market with the greatest import demand for petroleum products, distillate, and propane. 

6.3 POSSIBLE OCS PRODUCTION SUBSTITUTES 

A reduction in OCS oil and gas production would not lead to an equal reduction in the quantity of oil and 

gas demanded by energy markets. Instead, other energy sources—for example, more imports, onshore 

production, and coal, as well as a reduction in consumption—would substitute for most of the forgone 

OCS production. BOEM uses its Market Simulation Model (MarketSim) at the Proposed Program and 

PFP stages to estimate the amount and percentage of substitutes the economy would adopt in the absence 

of all, or even some, new OCS production. MarketSim is based on authoritative and publicly available 

estimates of price elasticities, which reflect the changes in quantities supplied and demanded in response 

to changes in price. MarketSim calculates what fuel sources would replace forgone OCS production. 

This includes increases in onshore oil and natural gas production, imports of oil and natural gas, fuel 

switching to coal or other sources of electricity, and reduced consumption. At the Proposed Program 

stage, BOEM will evaluate the energy market substitutions that would be required to replace the OCS 

production based on the Secretary’s decision on OCS leasing (see Part I). 

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Available documentation provides a detailed discussion of the data and methodology underlying 

MarketSim (Industrial Economics, Inc. 2017). In addition, the forthcoming Proposed Program and PFP 

analyses will contain specific estimates of production and quantities of other energy sources substituted 

for oil and gas should the Secretary select the “No Sale” option for any program area. 

Using the current laws, regulations, and technology assumptions inherent in the AEO’s Reference Case, 

the lost future OCS production in the absence of leasing under a new National OCS Program will be 

made up from energy industries likely to increase production or generation incrementally in response to 

small market changes. While this could, in some instances, be the more mature renewable energy 

technologies, the reality of many renewable energy sources is that their growth is predicated on policy 

initiatives rather than small relative changes in price. Additional renewable energy production is likely 

throughout the life of the leases issued under this National OCS Program, as domestic and global markets 

adjust to potential future policies and the technologies mature. Policies or other factors such as 

technological change could substantially increase the use of renewable energy sources during the life of 

this National OCS Program. Additional information on substitute energy sources is included in 

Forecasting Environmental and Social Externalities Associated with Outer Continental Shelf (OCS) Oil 

and Gas Development – Volume 2 (Industrial Economics, Inc. and SC&A, Inc. 2015). 

Data from EIA indicate, however, that renewable energy sources are not likely to be a major substitute for 

forgone OCS production. This likely is because different kinds of energy are used differently. For 

example, in terms of end use, about 24 percent of total U.S. energy consumption in 2016 was for 

transportation, of which 92 percent is fueled by petroleum (EIA 2017b).31 The predominant use of 

renewable energy in the U.S. is to generate electricity.32 

6.4 ENERGY MARKETS CONCLUSION 

The President’s energy strategy seeks to encourage energy exploration and production to maintain the 

United States’ position as a global energy leader. By providing opportunities for exploration, leasing, and 

development, and establishing regulatory certainty, additional domestic energy production provides 

energy security, jobs, and revenue for the United States. Through continued and expanded production, 

the OCS can enhance energy security by reducing dependence on foreign fuel sources. Further, the 

strategy recognizes that the United States needs to continue to pursue traditional sources of energy while 

encouraging development of renewable energy. New energy alternatives are gaining market share, but 

will take decades to displace oil and gas. Furthermore, oil and gas are used to make non-fuel products, 

such as plastics and fertilizer. All current commercial substitutes for oil and gas have market penetration 

limits, and none provide the prospect of fully replacing the versatility of oil and gas in the foreseeable 

future. 

The OCS Lands Act requires long-term planning for OCS oil and gas lease sales in the form of a National 

OCS Program. The program development process allows the Secretary to consider the current and likely 

31 Because of this huge market share, even recent advances in renewable fuel vehicle technology and large increases in consumer 

preference for electric and hybrid-electric vehicles are causing only small annual changes in market share. 32 Renewable energy can serve as part of the “base load” and generate at full capacity because of its minimal variable-input costs. 

While natural gas can be used as a base-load fuel as well, its use (in terms of both quantity and facility capacity) will vary 

throughout the day to provide immediate response to the constant fluctuations in demand for electricity. In addition, because 

natural gas is not costless as an input, demand for gas over time is responsive to its price. 

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future energy needs of the United States. This market analysis, consistent with the 2017 AEO, is focused 

in large part on assumptions reflecting current laws and policies. These assumptions provide consistent 

data for the Secretary to consider at this programmatic stage and allow him to see the potential impacts of 

his decisions. Within the five years of lease sales in the National OCS Program, the Secretary has the 

authority to limit the number of lease sales or areas available for lease for many reasons, which allows 

him to re-evaluate specific decisions to schedule lease sales once new information is available (e.g., 

prices, industry interest, future policies). Although domestic energy markets have undergone major 

changes in recent years with an abundance of new onshore production and low oil prices, the OCS 

remains a vital source of stable energy production. Regionally, OCS production contributes to the local 

energy markets. In the absence of leases under a new National OCS Program, energy markets would 

adjust and substitute energy sources would be necessary. 

6.5 OTHER USES OF THE OCS 

Section 18 (a)(2)(D) requires the Secretary to consider OCS regions “with respect to other uses of the sea 

and seabed, including fisheries, navigation, existing or proposed sea lanes, potential sites of deepwater 

ports, and other anticipated uses of the resources and space of the outer Continental Shelf.” This section 

provides a summary discussion about other uses of the OCS, including commercial fishing, state oil and 

gas activities, DOD and National Aeronautics and Space Administration (NASA) activities, tourism and 

recreation, commercial shipping and transport, coastal recreation (including recreational fishing and 

diving), and subsistence use. Unless otherwise noted, the principal source of information on the 

economic and public uses of the OCS and the surrounding coastal region for the different planning areas 

is BOEM’s report entitled Economic Inventory of Environmental and Social Resources Potentially 

Impacted by a Catastrophic Discharge Event within OCS Regions (BOEM 2014; hereafter referred to as 

the Economic Inventory Report). See the full Economic Inventory Report for detailed information and 

data on the economic and public use categories for each of the OCS planning areas. 

This section also provides information on the status of BOEM’s renewable energy leasing and non-energy 

marine minerals leasing33 in the planning areas. In 2009, USDOI announced the final regulations for the 

OCS Renewable Energy Program, which was authorized by the Energy Policy Act of 2005. These 

regulations provide a framework for issuing leases, easements, and rights-of-way for OCS activities that 

support production and transmission of energy from sources other than oil and natural gas. BOEM is 

responsible for overseeing OCS renewable energy development in Federal waters. Since the regulations 

were enacted, BOEM has worked diligently to oversee responsible renewable energy development on the 

OCS. 

Additionally, the OCS Lands Act assigns USDOI (which is then delegated to BOEM) responsibility for 

developing non-energy minerals on the OCS, such as sand, and to ensure related environmental protection 

associated with this development. Section 8(k) of the OCS Lands Act sets forth specific requirements for 

this activity. To date, all of the leases and agreements issued by BOEM’s Marine Minerals Program 

(MMP) have been negotiated, noncompetitive agreements for sand for beach nourishment and coastal 

restoration projects. Sand resource areas (often called borrow areas) dredged for these projects are 

33 BOEM’s MMP issues agreements and leases for offshore non-energy marine minerals, primarily for sand resources for use in 

coastal resiliency projects. Although there has been some interest expressed in rare earth minerals, manganese nodules, and gold 

no competitive leases have been issued. For more information, see http://www.boem.gov/Non-Energy-Minerals/. 

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typically in less than 100 feet of water depth. The MMP is also responsible for executing competitive 

lease agreements for other nonenergy minerals such as strategic mineral resources containing copper, 

lead, zinc, gold, platinum, and rare earth minerals. Developers have periodically expressed interest in 

obtaining leases to develop these resources; however, there have been no leases issued for these 

resources, and there are no pending lease requests at this time. For more information, see 

https://www.boem.gov/Marine-Minerals-Program/. 

Appendix A contains a summary of the individual comments that BOEM received in response to the RFI 

related to other uses of the OCS and potential conflicts between these other uses and oil and gas leasing 

activities. Many of the comments received from Federal agencies, state agencies, governor’s offices, and 

environmental advocacy groups highlight the critical importance of other existing, diverse coastal and 

ocean uses to both regional and statewide economies and request that BOEM fully consider any potential 

use conflicts. 

6.5.1 Alaska Region 

For purposes of this discussion, the 15 planning areas that comprise the Alaska OCS Region are grouped 

into three subregions: (1) the Arctic subregion comprised of Beaufort Sea, Chukchi Sea, and Hope Basin; 

(2) the Bering Shelf subregion comprised of Navarin Basin, North Aleutian Basin, St. George Basin, 

Norton Basin, St. Matthew-Hall, Aleutian Basin, and Bowers Basin; and (3) the Pacific Margin subregion 

comprised of Cook Inlet, Gulf of Alaska, Shumagin, Kodiak, and Aleutian Arc. Table 6-3 shows the 

other uses of the OCS for the Alaska Region. 

6.5.1.1 Commercial, Recreational, and Subsistence Uses 

Arctic Subregion 

Commercial activity in the Arctic subregion is limited. There is oil and gas production in state waters 

adjacent to the Beaufort Sea Planning Area. Fishing activity is limited to subsistence and recreational 

fishing because commercial fishing is prohibited in U.S. waters north of the Bering Strait (NPFMC 2009). 

Most recreational activity in the Arctic is limited by the harsh Arctic climate, difficulty of physically 

accessing the area, and logistics costs. The patterns and amount of vessel traffic in the Arctic are highly 

affected by seasonal variability and ice cover. Because of the limited infrastructure in the region, water 

transportation during ice-free months is an important means of transporting fuel and supplies for area 

residents. 

As part of the U.S. National Strategy for the Arctic Region, the Federal Government is preparing studies 

to understand baseline conditions and prepare for increased marine activity (ICCT 2015). Although 

diminished sea ice could result in an expanded timeframe for unaided navigation in the Arctic, constraints 

to increased vessel traffic include limited and/or outdated nautical charts, environmental factors such as 

weather conditions, and the lack of support infrastructure (ICCT 2015). 

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Table 6-3: Other Uses of the OCS within the Alaska Region 

Alaska 

Planning 

Area 

Activity 

Commercial 

Fishing 

Recreational 

Fishing 

Federal 

Agency 

Activity 

State 

Oil and 

Gas 

Activity 

Current 

OCS Oil 

and Gas 

Activity 

Subsistence 

Ports/ 

Shipping 

Routes 

Tourism 

Beaufort Sea X 

(NASA) 

X X X X 

Chukchi Sea X 

(DHS) 

X 

Hope Basin X 

(DHS) 

X 

Norton Basin X X X 

St. Georges 

Basin 

X X X X 

North 

Aleutian 

Basin 

X X X X 

Cook Inlet X X X X X X X 

Shumagin X X X 

Kodiak X X X X X 

Gulf of 

Alaska 

X X X 

(DOD) 

X X X 

Note: The Navarin Basin Planning Area is surrounded by open ocean, with negligible commercial activity or public uses. Due to negligible 

petroleum potential, the following planning areas are omitted from this table: St. Matthew-Hall, Aleutian Basin, Bowers Basin, and Aleutian Arc. 

Among Alaska Native communities such as the Iñupiat along the Beaufort and Chukchi seas, subsistence 

fishing and hunting practices hold a high cultural value and provide a substantial portion of many 

communities’ annual diets. A survey conducted by the Alaska Department of Fish and Game found that 

63 percent of households in the Arctic harvested game, and 92 percent of households used game; this 

demonstrates the wide sharing of subsistence foods (ADF&G 2014). Subsistence sharing and cooperation 

was further studied for three Arctic communities (Kaktovik, Wainwright, and Venetie). This study found 

that 30 percent of the households in these communities contributed between 76 and 93 percent of 

harvested food to be shared and distributed among the community (Kofinas et al. 2016). This reliance on 

harvesters could make the subsistence system vulnerable. 

Bering Shelf Subregion 

Because the Navarin Basin Planning Area is surrounded by open ocean, commercial activity and public 

use of marine resources in the planning area are both negligible. In addition, BOEM estimates that the 

UTRR in the Bowers Basin Planning Area and the Aleutian Basin Planning Area are negligible, thus the 

Economic Inventory Report and this analysis do not present information on these planning areas. Hence, 

the discussion of the economic and public use of resources in and along the Bering Shelf subregion 

focuses on the remaining four planning areas (North Aleutian Basin, St. George Basin, St. Matthew-Hall, 

and Norton Basin). The most important other use of the OCS in terms of economic significance in these 

planning areas is commercial fishing (BOEM 2014). Commercial fishing is the primary source of 

employment for residents of the North Aleutian Basin area, and the Bristol Bay area is one of the largest 

Alaska fisheries in terms of total fish harvested and processed. Combined with Bristol Bay, Kuskokwim 

Bay (St. Matthew-Hall region) is considered part of the largest sockeye salmon fishery in the world. 

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While tourism and commercial shipping are less significant overall, they are important to many local 

economies. Tourism revolves almost exclusively around outdoor recreation, including recreational 

fishing, sport hunting, hiking, and wildlife viewing in the North Aleutian Basin and the Norton Basin 

(concentrated in Nome), and the St. Matthew-Hall area is one of the great birding areas of North America. 

Recreational activity in and near the St. George Basin Planning Area is limited due to its remoteness, with 

most fishing and hunting for subsistence rather than for recreation. The Port of Bristol Bay 

(North Aleutian Basin) and the Port of Nome (Norton Basin) service nearby villages and communities. 

The St. George Basin and the St. Matthew-Hall areas do not have any major commercial ports; however, 

the “Great Circle” shipping route between the Pacific Northwest and Asia passes through the St. George 

Basin Planning Area. 

Recreational angling represents the most economically significant public use of natural resources in and 

near the Bristol Bay area (St. Matthew-Hall Basin). In 2009, approximately $60 million was spent in 

Alaska specifically for the purpose of recreational fishing trips in the Bristol Bay area (USEPA 2014). 

Most of the fishing by local residents in the other areas is for subsistence rather than for recreation. 

Subsistence fishing and hunting is a critically important public use of coastal and marine resources across 

all four planning areas. Communities engage in subsistence hunting and fishing for their economic, 

social, cultural, and spiritual value, and to meet basic nutritional needs. In 2010, Alaska Native peoples 

comprised approximately 15 percent of the state’s population (USCB 2010). Alaska Native peoples 

comprise a large percentage of the population along the North Aleutian Basin and St. Matthew-Hall 

planning areas (USCB 2015). 

Pacific Margin Subregion 

Commercial fishing, seafood harvesting and processing, tourism and recreation, and commercial shipping 

are all important industries in and adjacent to the Pacific Margin subregion. Both commercial fishing and 

seafood harvesting and processing are economically important industries along the Gulf of Alaska, 

Aleutian Arc, Kodiak, and Shumagin planning areas, and while somewhat less important along Cook 

Inlet, they are still economically important. Commercial fishing in the Gulf of Alaska and near the 

Aleutian Arc Planning Area is critical to the regional and state economy (BOEM 2014). Fish harvesting 

and processing also represent the largest source of jobs and earnings on Kodiak Island (particularly 

processing) and are the most important commercial industries in the Shumagin Planning Area. Tourism 

is a critical component of the Cook Inlet and Gulf of Alaska planning areas’ economies, but is fairly 

limited in and near the Kodiak, Shumagin, and Aleutian Arc planning areas. 

For the Gulf of Alaska area, visitor industry-related employment accounts for 13 percent of all 

employment in Juneau and roughly 20 percent of all sales tax revenue collected by the city 

(JC&VB 2015). The subregion is also important for commercial shipping. The Port of Valdez in the 

Gulf of Alaska is the largest port in Alaska and one of the 20 largest in the United States as defined by 

total traffic, largely due to oil shipments. Oil and gas production in state waters adjacent to the Pacific 

Margin subregion currently is limited to the Cook Inlet Planning Area. The Port of Anchorage on the 

eastern end of Cook Inlet is an essential port for many Alaska residents, since more than 85 percent of all 

consumer goods are provided to Alaska’s population through the port (Port of Anchorage 2016). In 

addition, thousands of commercial vessels pass through the Gulf of Alaska, Kodiak, Shumagin, and 

Aleutian Arc annually along the “Great Circle” shipping route from the Pacific Northwest to Asia. 

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Important public uses in and along the subregion include coastal recreation, recreational fishing and 

hunting, and subsistence fishing and hunting. The Cook Inlet Planning Area is a popular site for outdoor 

recreational activities, particularly fishing, hiking, boating, hunting, and wildlife viewing. Subsistence 

fishing and hunting are critically important public uses of coastal and marine resources in the Cook Inlet 

Planning Area. Communities engage in subsistence hunting and fishing for their economic, social, 

cultural, and spiritual value, and to meet basic nutritional needs. While species of salmon are the primary 

subsistence source in and near the Cook Inlet Planning Area, halibut and shellfish (particularly crab) are 

also important. Subsistence fishing and hunting make up a substantial portion of many communities’ 

annual diets. As described in the Final Environmental Impact Statement for Cook Inlet Lease Sale 244, 

data indicate that large amounts of subsistence foods are harvested in the geographic areas adjacent to the 

Cook Inlet Planning Area (BOEM 2016). 

6.5.1.2 Military and NASA Uses 

DOD conducts training, testing, and operations in offshore operating and warning areas, undersea warfare 

training ranges, and special use or restricted airspace on the OCS. These activities are critical to military 

readiness and national security. DOD commented in response to the RFI that a detailed assessment of the 

compatibility of military and OCS oil and gas development will be submitted. The U.S. Navy utilizes the 

airspace, sea surface, subsurface, and seafloor of the OCS for events ranging from instrumented 

equipment testing to live-fire exercises. The U.S. Air Force conducts flight training and systems testing 

over extensive areas on the OCS. The U.S. Marine Corps amphibious warfare training extends from 

offshore waters to the beach and inland. The Department of Homeland Security’s U.S. Coast Guard 

conducts search and rescue missions and coordinates with the U.S. Navy to conduct ice thickness and 

acoustic surveys. 

BOEM received comments from NASA regarding concern for potential conflicts that could occur in the 

Beaufort Sea Planning Area from NASA activities at the Poker Flat Research Range, a University of 

Alaska Fairbanks-owned facility outside of Fairbanks, Alaska. NASA indicated it will provide an 

updated analysis of mission compatibility with OCS oil and gas development for the planning areas that 

are included in the DPP decision. 

6.5.1.3 Renewable Energy 

BOEM has not received applications for renewable energy or marine mineral leasing in any of the Alaska 

planning areas and is not aware of any specific plans or proposals to develop OCS renewable energy 

resources in these areas at this time. Therefore, BOEM does not expect that commercial leasing for OCS 

renewable energy resources would occur in the Alaska planning areas during the 2019–2024 timeframe. 

Any renewable energy leasing that could occur during the approximate 40- to 70-year lifespan of the 

producing leases issued during the 2019–2024 Program will need to be coordinated during the later stages 

of BOEM’s oil and gas leasing process (e.g., lease sale, exploration plan, and development and 

production plan stages). 

6.5.1.4 Non-energy Marine Minerals 

Although BOEM has not issued any leases or agreements for non-energy, marine minerals in the Alaska 

planning areas, there have been recent inquiries regarding potential prospecting and competitive leasing 

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of strategic mineral resources (e.g., gold) offshore Nome in the Norton Basin Planning Area. It is 

possible that competitive leasing for gold could be further developed within the timeframe of the 

2019–2024 Program. 

6.5.2 Pacific Region 

The Pacific OCS Region comprises four planning areas: Washington-Oregon, Northern California, 

Central California, and Southern California. Table 6-4 shows the other uses of the OCS within the Pacific 

Region. 

Table 6-4: Other Uses of the OCS within the Pacific Region 

Activity 

Planning Area 

Washington/ 

Oregon 

Northern 

California 

Central 

California 

Southern 

California 

Commercial 

Fishing X X 

Recreational 

Fishing X X X X 

Federal Agency 

Activity 

X 

(DOD) 

X 

(DOD) 

X 

(DOD) 

Current OCS Oil 

and Gas Activity X 

Potential OCS 

Renewable 

Energy 

X X 

Subsistence X 

Ports/ Shipping 

Routes X X X 

Tourism X X X X 

6.5.2.1 Commercial, Recreational, and Subsistence Uses 

Although important throughout the region, commercial fisheries in and near the Washington/Oregon 

Planning Area (especially near Washington) and the Southern California Planning Area are particularly 

essential from an economic perspective. In 2009, the commercial fishing industry provided roughly 

$3 billion in value added to Washington (contribution to state GDP), while the waters in and near the 

Southern California Planning Area account for roughly 75 percent of California’s total commercial 

fishing landings, by pound, and contribute more than $5 billion in total value added to California’s state 

GDP (BOEM 2014). 

The ocean-dependent tourism and recreation sector is also significant, with counties near the Central 

California and Southern California planning areas each accounting for more than $7 billion in total value 

added in 2009, and counties near the Washington/Oregon Planning Area accounting for more than 

$3.5 billion in total value added in 2009 (BOEM 2014). Within California, commercial shipping activity 

is concentrated in ports near the Central California Planning Area (San Francisco) and the Southern 

California Planning Area (Los Angeles and Long Beach, two of the United States’ ten largest ports 

measured in terms of cargo tonnage). Seattle, the 26th largest port in the United States based on cargo 

tonnage, is the largest port near the Washington/Oregon Planning Area. 

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USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Outdoor coastal recreation is an important use of coastal resources along the Washington, Oregon, and 

California coasts. Washington and Oregon have almost a dozen national wildlife refuges (NWRs) and a 

few large national parks (NPs) along their coasts that support coastal recreational activities such as beach 

visitation, bird watching, and wildlife and scenery viewing. Washington is one of the top five states in 

the United States for scuba diving in terms of the number of participants. The coast of California is also 

home to a variety of NWRs and NPs that help support a range of outdoor recreational activities, 

particularly hiking, boating, and wildlife viewing in the northern region, as well as beach visitation, 

swimming, and surfing in the central and southern regions. Recreational fishing represents one of the 

most significant public uses of coastal resources in and near the Pacific Region, particularly in 

Washington and southern California in terms of economic impacts (with annual expenditures in 2011 

exceeding $1.8 billion for Washington and $4.4 billion for California) (ASA 2017). 

Data on subsistence fishing and shellfish harvesting in the Pacific region is generally limited and 

primarily anecdotal. Washington and Oregon are home to a variety of indigenous, Asian, and Pacific 

Islander communities who rely on subsistence fishing as both a cultural tradition and an important 

economic staple. In California, official information on subsistence fishing is included within recreational 

fishing data. Subsistence fishing could be most prevalent in those areas designated as “fishing 

communities” by the National Oceanic and Atmospheric Administration (NOAA), defined as cities and 

towns with strong ties to commercial and/or recreational fishing. 

6.5.2.2 Military Uses 

DOD conducts training, testing, and operations in offshore operating and warning areas, undersea warfare 

training ranges, and special use or restricted airspace on the OCS. These activities are critical to military 

readiness and to national security. The U.S. Navy utilizes the airspace, sea surface, subsurface, and 

seafloor of the OCS for events ranging from instrumented equipment testing to live-fire exercises. The 

U.S. Air Force conducts flight training and systems testing over extensive areas on the OCS. The 

U.S. Marine Corps’ amphibious warfare training extends from offshore waters to the beach and inland. 

Some of the most extensive offshore areas used by DOD include U.S. Navy at-sea Operational Areas 

(OPAREAs). Testing and training does not occur on all days of the year, but could occur during any 

season. These activities vary depending on where in the OPAREA they occur (e.g., open versus 

nearshore water) and could be concentrated within a smaller geographic area than the OPAREA footprint. 

The Pacific Northwest OPAREA is off the Washington and Oregon coasts, and the Southern CaliforniaPoint Mugu OPAREA is off the central and southern California coasts and extends into waters south of 

the U.S.-Mexico border. Vandenberg Air Force Base is on the coast in the Southern California Planning 

Area and has an active launch program that has been taken into account via lease sale stipulations in the 

past. DOD commented in response to the RFI that a detailed assessment of the compatibility of military 

and OCS oil and gas development will be submitted. 

6.5.2.3 Renewable Energy 

In the Pacific, BOEM continues to work closely with states and other stakeholders to facilitate OCS 

renewable energy development off Oregon and California.34 In Oregon, the Northwest National Marine 

34 BOEM is also working to develop renewable energy offshore Hawaii; however, there are negligible oil and gas resources 

offshore Hawaii so this area is not analyzed for the National OCS Program. See Chapter 1 for a brief discussion. 

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USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Renewable Energy Center at Oregon State University (NNMREC-OSU) has applied to BOEM for a 

research lease offshore Newport, Oregon. The proposed research lease would consist of four test berths 

to demonstrate the viability of wave energy off the coast of the United States by providing a gridconnected ocean test facility for prototype and utility scale wave energy devices. In 2014, BOEM 

determined that there was no competitive interest offshore Newport, Oregon, where NNMREC-OSU has 

proposed the research facility. BOEM is working with the Federal Energy Regulatory Commission as a 

Cooperating Agency in preparing environmental documents for the proposed project. The location of the 

project area is shown in Figure 6-10. 

In California, BOEM received an unsolicited request for a commercial offshore wind lease from Trident 

Winds, LLC (Trident Winds) in January 2016. To determine competitive interest, BOEM published a 

Request for Interest in the Federal Register on August 18, 2016, to determine whether or not other 

companies were interested in developing in areas proposed in the unsolicited lease request. BOEM 

received one expression of interest from Statoil Wind US, LLC. Therefore, BOEM has initiated the 

competitive planning and leasing process with the State of California for possible future leasing for 

offshore wind development. BOEM and the state are working together with stakeholders to identify and 

collect relevant data and information on existing ocean resources and uses. These data sets are being 

collected in an online data portal to facilitate future decision making about offshore wind development 

along the California coast. Planning activities are shown in Figure 6-10. 

6.5.2.4 Non-Energy Marine Minerals 

BOEM has not issued any leases or agreements for non-energy marine minerals in the Pacific planning 

areas; however, the State of California has expressed interest in identifying OCS sand resources for 

remedial nourishment of severely eroded coastal beaches. The management of coastal sand resources is 

under consideration by the Coastal Sediment Management Workgroup35 and the potential identification of 

OCS sand resources to support future needs is currently being evaluated. 

35 The Coastal Sediment Management Workgroup is a taskforce of state, federal, regional, and local entities chaired by the 

U.S. Army Corps of Engineers South Pacific Division and the California Natural Resources agency. BOEM is a part of the 

workgroup. 

Planning Area Location Considerations 6-23 January 2018 
USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Figure 6-10: Pacific Region Renewable Energy Planning Activities and Project Lease Area 

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USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

6.5.3 Gulf of Mexico Region 

The GOM Region comprises three planning areas: the Western, Central, and Eastern GOM planning 

areas. The most notable other uses of the OCS in terms of economic contribution are coastal tourism and 

recreation, commercial fishing and seafood harvesting, and commercial shipping. Table 6-5 shows the 

other uses of the OCS within the GOM Region. 

Table 6-5: Other Uses of the OCS within the Gulf of Mexico Region 

Activity Planning Area 

Western GOM Central GOM Eastern GOM 

Commercial 

Fishing X X X 

Recreational 

Fishing X X X 

Federal Agency 

Activity 

X 

(DOD) 

X 

(DOD) 

X 

(DOD) 

State Oil and 

Gas Activity X X X 

Current OCS Oil 

and Gas Activity X X X 

Marine Minerals 

Program 

Recipient 

X X X 

Subsistence X 

Ports/ Shipping 

Routes X X 

Tourism X X X 

6.5.3.1 Commercial, Recreational, and Subsistence Uses 

The commercial fishing and seafood industries contribute billions to state GDP on an annual basis (most 

notably in and along the Eastern GOM Planning Area, with more than $4 billion in GDP for the area 

[BOEM 2014]). The commercial fishery sector is largest in Louisiana, followed by Texas and then 

Florida. However, Florida’s seafood industry contributes most to GDP because of its contributions 

further along the seafood supply chain (e.g., processors, retailers). Aquaculture, or the farming of seafood 

species, is becoming more common along the Gulf coast. As stated in its comment letter, NMFS would 

work with BOEM to identify potential conflicts between oil and gas activities and aquaculture activities. 

This coordination would occur during the later stages of BOEM’s oil and gas leasing process (e.g., lease 

sale, exploration plan, and development and production plan stages). Commercial shipping is also 

important economically. As measured by the amount of cargo flowing through Gulf ports on an annual 

basis, more than half of the 20 largest U.S. ports are along the Gulf coast (mostly along the Central and 

Western GOM planning areas) (BOEM 2014). Three of the five Gulf coast states—Alabama, Louisiana, 

and Texas—have had some historical oil and gas exploration activity and currently produce oil and gas in 

state submerged lands.36 

36 For recent information on state oil and gas leasing programs in the GOM, see Chapter 3 of BOEM’s Final Multisale 

Environmental Impact Statement for Gulf of Mexico Lease Sales 249, 250, 251, 252, 253, 254, 256, 257, 259, and 261 

(BOEM 2017). 

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Millions of individuals participate in a variety of recreational activities in the region’s coastal 

environment each year, including recreational fishing, boating, beach visitation, wildlife viewing, and 

swimming. Texas, Louisiana, and Florida have significantly more coastline and more coastal population 

centers than Alabama or Mississippi. However, the tourism and recreation industries in Alabama and 

Mississippi still compose sizable portions of GDP as a percent of each state’s total employment. On an 

annual basis, coastal tourism and recreation industries contribute more than $1 billion in GDP to the states 

adjacent to the Western and Central GOM planning areas, and more than $6 billion in GDP for the 

Eastern GOM Planning Area, generated from the counties in western Florida (BOEM 2014). 

While very little data exist to track their economic contributions, subsistence fishing and seafood 

harvesting are also important public uses of coastal and marine resources along the three GOM planning 

areas, particularly to rural communities. Traditional subsistence harvesting, including fishing and 

hunting, continues among some ethnic and low-income groups (MMS 2003). Several groups living along 

the Louisiana coast are central to the culture of the region and rely on fisheries and related marine 

resources. The Cajun population fishes and recreationally harvests fish and shellfish from the bayous as 

part of its subsistence (Henry and Bankston 2002). The United Houma Nation and the Chitmacha Tribe 

in southeastern Louisiana depend on subsistence diets, recovering foods from coastal areas. Vietnamese 

fishers, who fish in the near offshore, retain up to 25 percent of their catch for their families and also to 

use when bartering (Alexander-Bloch 2010). 

6.5.3.2 Military Uses 

DOD conducts training, testing, and operations in offshore operating and warning areas, undersea warfare 

training ranges, and special use or restricted airspace on the OCS. These activities are critical to military 

readiness and to national security. The U.S. Navy utilizes the airspace, sea surface, subsurface, and 

seafloor of the OCS for events ranging from instrumented equipment testing to live-fire exercises. The 

U.S. Air Force conducts flight training and systems testing over extensive areas on the OCS. The U.S. 

Marine Corps amphibious warfare training extends from offshore waters to the beach and inland. 

Some of the most extensive offshore areas used by DOD include U.S. Navy at-sea training areas. 

Training and testing could occur throughout the GOM OCS waters, but will be concentrated in 

OPAREAs and testing ranges. These activities could vary depending on where they occur (e.g., open 

versus nearshore water). Major testing and training areas in the GOM include the Gulf of Mexico Range 

Complex, the Naval Surface Warfare Center, Panama City Division, and the Key West Complex off the 

southwestern tip of Florida. 

DOD and USDOI will continue to coordinate extensively under the 1983 Memorandum of Agreement, 

which states that the two parties shall reach mutually acceptable solutions when the requirements for 

mineral exploration and development and defense-related activities conflict. DOD commented in 

response to the RFI that a detailed assessment of the compatibility of military and OCS oil and gas 

development will be submitted. 

6.5.3.3 Renewable Energy 

BOEM has not received applications for renewable wind energy leasing in the GOM Region and is not 

aware of any specific plans or proposals to develop OCS renewable energy resources in this area at this 

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USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

time. However, BOEM is conducting renewable energy studies in the GOM and anticipates future 

renewable energy leases. Noting that leases with discoveries of oil or gas can be held for as long as 

commercial production continues, any renewable energy leasing that could occur during the 

approximately 40- to 70-year lifespan of the producing leases issued during the 2019–2024 Program will 

need to be coordinated during the later stages of BOEM’s oil and gas leasing process (e.g., lease sale, 

exploration plan, and development and production plan stages). 

6.5.3.4 Non-Energy Marine Minerals 

BOEM has issued leases and agreements, and anticipates receiving future requests, for OCS sediment for 

coastal restoration projects along the GOM, specifically, offshore the western coast of Florida, and the 

coasts of Mississippi and Louisiana (see Figure 6-11). BOEM’s GOM MMP expects to be a significant 

resource to the Gulf coastal region as funds from the Resources and Ecosystems Sustainability, Tourist 

Opportunities, and Revived Economies of the Gulf Coast States Act (commonly referred to as the 

RESTORE Act; P.L. 112-141, 126 Stat. 407 [2012]) are used for restoration projects by coastal states. 

Typically, resource borrow areas are in water depths of less than 100 feet and are in close proximity to the 

coast. Significant sediment resources, shown in Figure 6-11, are those sand resources that are essential to 

coastal restoration initiatives in the GOM Region. OCS sediment resources refer to the sediment 

deposit(s), including clay, silt, sand, and gravel-size particles and shell, found on or below the surface of 

the seabed on the OCS as defined in Section 2(a) of the OCS Lands Act (43 U.S.C. § 1331(a)). BOEM 

has issued a Notice to Lessees and Operators and Pipeline Right-of-Way Holders to provide guidance for 

the avoidance and protection of significant sand resources. 

Figure 6-11: Gulf of Mexico Region Sand Borrow Areas and Significant Sand Resources 

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USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

6.5.4 Atlantic Region 

The Atlantic OCS Region comprises four planning areas: North Atlantic, Mid-Atlantic, South Atlantic, 

and Straits of Florida. Table 6-6 shows the other uses of the OCS within the Atlantic Region. 

Table 6-6: Other Uses of the OCS within the Atlantic Region 

Activity Planning Area 

North Atlantic Mid-Atlantic South Atlantic Straits of Florida 

Commercial 

Fishing X X X X 

Recreational 

Fishing X X X X 

Federal Agency 

Activity 

X 

(DOD) 

X 

(DOD, NASA) 

X 

(DOD) 

X 

(NASA) 

Potential OCS 

Renewable 

Energy 

X X X 

Marine Minerals 

Program 

Recipient 

X X X X 

Subsistence X X X 

Ports/ Shipping 

Routes X X X X 

Tourism X X X X 

6.5.4.1 Commercial, Recreational, and Subsistence Uses 

Commercial and recreational fishing, ocean-dependent tourism, and commercial shipping and 

transportation are important economic uses in and along all the Atlantic planning areas. The North 

Atlantic supplies much of the fish and shellfish consumed in the United States, with Maine having the 

highest landings value (almost $600 million), followed by Massachusetts (more than $500 million) for 

2015 (NMFS 2015). The economic impacts of commercial fishing along the entire Mid-Atlantic Planning 

Area total almost $7 million in total value added (GDP); the industry is especially large in New York and 

New Jersey, which contribute $2.2 and $2.8 million to the GDP, respectively (NOAA 2012). 

North Atlantic Planning Area ports handle roughly 10 percent of the United States’ total imports and 

exports, and the Port of New York is one of the United States’ five largest ports. Ports located in the 

Mid-Atlantic Planning Area handle approximately 5 percent of total U.S. waterborne traffic, and Norfolk 

Harbor is one of the 20 largest ports in the United States. While the South Atlantic Planning Area does 

not have as many adjacent ports as the other planning areas, three are in the top 40 ports in the United 

States in terms of traffic. The Straits of Florida is one of the most heavily trafficked shipping areas in the 

world, with more than 40 percent of the world’s marine commerce passing through the region every year. 

Ocean-dependent tourism in and along the North Atlantic Planning Area is an enormous industry, with 

the economic impacts for New York by far the highest (more than $16 billion in total value added in 

2009). Ocean-dependent tourism is also a significant economic use for the Mid-Atlantic, South Atlantic, 

and Straits of Florida planning areas (accounting for over $6.7 billion, $4.4 billion, and $6 billion in value 

added in 2009, respectively, to adjacent coastal areas) (BOEM 2014). Ocean-dependent tourism is a 

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particularly important contribution to each state’s GDP for New York ($33.9 billion), New Jersey 

($10.8 billion), Florida ($7.7 billion), Virginia ($2.9 billion), Maryland ($2.5 billion), and South Carolina 

($2.2 billion) (BOEM 2014). 

The Atlantic coastal region contains numerous NWRs (roughly 70), NPs, and national seashores (NSs), as 

well as many state parks and recreational areas where the public engages in various recreational activities. 

Beach visitation, swimming, wildlife viewing, boating, and fishing are the most popular coastal activities 

across the Atlantic states. Beach recreation is critically important to the Florida economy. Among the 

states adjacent to the North Atlantic Planning Area, the economic impacts of recreational fishing were 

highest in New York, followed by New Jersey and Massachusetts for 2011 (ASA 2017). In 2009, 

recreational fishing expenditures resulted in total value added in the Mid-Atlantic economy of more than 

$2 billion (with North Carolina accounting for more than half); more than $1.3 billion in the South 

Atlantic economy (with eastern Florida accounting for the vast majority); and nearly $2 billion to the 

economies in the counties near the Straits of Florida Planning Area (BOEM 2014). 

Very little data exist on subsistence fishing and shellfish harvesting in and along the Atlantic planning 

areas, and what information is available is largely informal or speculative. It could be most prevalent in 

those areas designated as “fishing communities” by NOAA, which are defined as such due to their strong 

ties to commercial and recreational fishing. Overall, NOAA has identified 47 fishing communities near 

the South Atlantic Planning Area and 9 near the Straits of Florida Planning Area (Jepson et al. 2005). 

According to NOAA’s profiles of fishing communities in the Northeast, the limited information available 

on subsistence fishing and harvesting is for the urban communities, and suggests a relative importance to 

immigrant populations in these areas. 

6.5.4.2 Military and NASA Uses 

DOD conducts training, testing, and operations in offshore operating and warning areas, undersea warfare 

training ranges, and special use or restricted airspace on the OCS. These activities are critical to military 

readiness and to national security. The U.S. Navy utilizes the airspace, sea surface, subsurface, and 

seafloor of the OCS for events ranging from instrumented equipment testing to live-fire exercises. The 

U.S. Air Force conducts flight training and systems testing over extensive areas on the OCS. The 

U.S. Marine Corps amphibious warfare training extends from offshore waters to the beach and inland. 

Some of the most extensive offshore areas used by DOD include U.S. Navy at-sea training areas. 

Training and testing could occur throughout the U.S. east coast OCS waters, but will be concentrated in 

OPAREAs and testing ranges. On the east coast, a major testing range includes the Naval Undersea 

Warfare Center, Division Newport. In the North Atlantic, U.S. Navy range complexes include Atlantic 

City, Narragansett Bay, and Boston; in the Mid-Atlantic, range complexes include Virginia Capes, Cherry 

Point, and portions of Chesapeake Bay; in the South Atlantic, range complexes include the Jacksonville 

Range Complex. DOD commented in response to the RFI that a detailed assessment of the compatibility 

of military and OCS oil and gas development will be submitted. 

In addition to military installations, there are several facilities along the U.S. Atlantic coast operated by 

NASA that incorporate marine components. Wallops Flight Facility on Wallops Island, Virginia, is a key 

location for operational test, integration, and certification of NASA and commercial orbital launch 

technologies. The facility has an offshore launch hazard area in adjacent waters. It also supports many 

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Federal agency activities, including U.S. Navy activities in the Virginia Capes OPAREA. Farther south 

in the Straits of Florida Planning Area, NASA operates the Kennedy Space Center, which is on Cape 

Canaveral and most well-known for its function as a former launch site for the U.S. space shuttles. The 

waters around the Kennedy Space Center are recognized as a de facto marine reserve since human entry is 

prohibited there. 

BOEM received comments from NASA stating that a primary concern is that future oil and gas 

development in the Atlantic Ocean would result in the need to protect additional persons and property 

when conducting launch operations. NASA indicated it will provide an updated analysis of mission 

compatibility with OCS oil and gas development for the relevant planning areas that are included in the 

DPP decision. 

6.5.4.3 Renewable Energy 

To date, BOEM activities include issuing 13 wind energy leases off the Atlantic coast, with site 

characterization surveys and site assessment activities (i.e., construction and operation of meteorological 

towers and buoys) occurring during the 2019–2024 timeframe. Up to three construction and operations 

plans are anticipated to be submitted in late 2017 and early 2018, and construction of offshore wind 

facilities could begin in the 2019–2024 timeframe. BOEM is considering offering additional areas for 

lease, and is processing unsolicited requests for leases and rights-of-way grants. An overview of the 

current and proposed lease areas is provided in Figure 6-12, which also shows oil and gas leases in 

Canadian waters. Information is provided for individual planning areas to capture the relevant level of 

detail. 

North Atlantic Planning Area 

In 2010, the first commercial OCS renewable energy lease in the United States was issued to Cape Wind 

Associates. On September 9, 2014, BOEM completed its review of the Facility Design Report and 

Fabrication and Installation Report submitted by Cape Wind Associates for a proposed 468-MW wind 

power facility, allowing Cape Wind Associates to proceed with its project. The project is in a 

noncompetitive leased area of Nantucket Sound off the coast of Massachusetts. 

On July 31, 2013, BOEM held an auction for the Rhode Island/Massachusetts Wind Energy Area, which 

was the first competitive lease sale in the U.S. In September, 2013, BOEM executed two commercial 

wind energy leases for Deepwater Wind New England, LLC (Deepwater Wind). On December 19, 2014, 

BOEM executed a right-of-way grant for an 8-nm-long, 200-foot-wide corridor in Federal waters to 

Deepwater Wind for the Block Island Transmission System to install a submarine cable in support of the 

Nation’s first operational offshore wind farm, Block Island Wind Farm, in Rhode Island state waters. In 

March, 2015, BOEM executed commercial wind energy leases with RES America Developments, Inc. 

(RES) and Offshore MW, LLC approximately 13 miles off the coast Massachusetts. In June 2015, 

BOEM approved the assignment of the RES commercial lease to Bay State Wind, LLC. In January 2017, 

BOEM executed a commercial wind energy lease with Statoil approximately 11 miles off the coast of 

New York. 

Planning Area Location Considerations 6-30 January 2018 
 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Figure 6-12: Current and Proposed Renewable Energy Projects on the Atlantic OCS 

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USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Finally, several companies have expressed interest in additional leasing areas and BOEM anticipates 

holding one or more competitive auctions and potentially executing additional leases in the North Atlantic 

during the next several years, possibly within the 2019–2024 timeframe. Renewable energy leasing that 

could occur during the approximately 40- to 70-year lifespan of the producing leases issued during the 

2019–2024 Program will need to be coordinated during the later stages of BOEM’s oil and gas leasing 

process, if oil and gas leasing occurs (e.g., lease sale, exploration plan, and development and production 

plan stages). 

Mid-Atlantic Planning Area 

In November 2012, BOEM executed a commercial wind energy development lease with Bluewater Wind, 

LLC (Bluewater) approximately 11 nm off the coast of Delaware. In December 2016, BOEM approved 

the assignment of Bluewater’s lease to Garden State Offshore Energy (GSOE). In November 2013, 

BOEM executed a commercial wind energy development lease with Dominion Energy for an area 

approximately 26 miles off the coast of Virginia Beach, Virginia. In August 2014, BOEM held a lease 

sale for the Maryland wind energy area, about 10 nm off the coast of Ocean City. U.S. Wind, Inc. 

submitted the winning bid for both lease areas. 

In addition to commercial leasing BOEM also issues renewable energy leases when appropriate to state 

and Federal agencies for research purposes that support the future production, transportation, or 

transmission of renewable energy. BOEM executed a research lease with the Virginia Department of 

Mines, Minerals, and Energy (DMME). Within the research lease, DMME has proposed to demonstrate a 

grid-connected, 12-MW offshore wind test facility in an area adjacent to the Dominion Energy 

commercial lease, with construction to be completed in 2020. In March 2016, BOEM approved the 

Research Activities Plan and executed a project easement for the transmission line to shore. Any 

additional renewable energy leasing that could occur during the approximately 40- to 70-year lifespan of 

the producing leases issued during the 2019–2024 Program will need to be coordinated during the later 

stages of BOEM’s oil and gas leasing process, if oil and gas leasing occurs (e.g., lease sale, exploration 

plan, and development and production plan stages). 

South Atlantic Planning Area 

In March 2017, BOEM held an auction for the Kitty Hawk Lease Area approximately 27 nm offshore 

North Carolina. The winner of that auction was Avangrid Renewables, LLC. The Wilmington East Wind 

Energy Area and Wilmington West Wind Energy Area are both being evaluated for commercial 

competitive leasing offshore North Carolina and stakeholder discussions continue. In South Carolina, a 

Call and an NOI to prepare an EA were both published in December 2015. BOEM received a single 

qualified nomination for the Grand Strand Call Area from U.S. Wind Inc. and is evaluating the comments 

and nomination received on the area for commercial leasing. Planning with respect to renewable energy 

development in both of these areas is in the early stages, and the prospects are uncertain; however, 

commercial leasing could proceed during the 2019–2024 timeframe. 

Straits of Florida Planning Area 

Four areas along the Straits of Florida Planning Area’s southeastern coast were previously nominated for 

interim policy leasing relating to ocean current power. Experts believe these locations are within one of 

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USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

the prime areas for ocean current power development due to the large volume and steady flow of the Gulf 

Stream. While the ocean current power industry is perhaps the most nascent of the offshore renewable 

energy sources, multiple developers, utilities, and academic institutions have expressed interest in the 

resource potential. Although BOEM is aware of some commercial interest in marine hydrokinetics 

project leasing offshore Florida, renewable energy development in this area is not certain at this time. 

6.5.4.1 Non-Energy Marine Minerals 

Through November 2017, BOEM has issued 39 agreements for approximately 69 million cubic yards of 

OCS sand for beach nourishment and coastal restoration projects along the Atlantic coast from New 

Jersey south to Florida. Atlantic coast states that have utilized OCS sand include New Jersey, Maryland, 

Virginia, North Carolina, South Carolina, and Florida. Typically, the borrow areas are in less than 

100 feet of water and within 10 miles of the coast. Some recent interest has been expressed in the 

potential future use of OCS sand offshore New York, Delaware, and the New England states. BOEM has 

also been working closely with the states and other Federal partners to identify new potential Federal sand 

resource areas. There has been an increasing interest in sand from the OCS for beach nourishment and 

coastal restoration projects, especially in light of recent storm activity such as Hurricanes Sandy, 

Matthew, and Irma. 

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USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Chapter 7 Environmental Consideration Factors and Concerns 

7.1 ENVIRONMENTAL SETTING AND ECOLOGICAL CHARACTERISTICS 

The environmental setting of an area where oil and gas leasing activities could occur is defined by various 

geological, geographical, and ecological characteristics. Section 5.1 includes a discussion of the 

hydrocarbon resources and a basic explanation of the geologic plays in each of the planning areas. The 

geographical setting includes the location of the region and its associated planning areas, as well as any 

unique physical characteristics. 

The ecological characteristics that define the environmental setting encompass all facets of a particular 

group of related species, habitats, or other ecologically significant parameters. The same general 

environmental resource areas (e.g., marine mammals, air quality) exist for all of the regions in which oil 

and gas leasing could occur; however, the relative importance of a given resource can vary depending on 

the geographic location. This can be due to many factors, such as relative abundance, sensitivity, the 

presence of federally protected species, the level of activity that occurs, or the presence of multiple human 

uses in an area that could impact the same resources. Resources include the physical and biological 

components of the larger ecosystem; environmental resource areas are defined components that are 

closely related, such as species groups (e.g., marine mammals) or interrelated habitats such as those that 

occur on the sea floor. 

The sections below provide a brief overview of the environmental setting by region. Relevance of the 

characteristics of a region are often defined through distinctiveness of a resource, ecological importance, 

potential for impact, resiliency, state or Federal laws and policies, and ecosystem service value. For 

example, the Endangered Species Act (P.L. 93-205, 16 U.S.C. 1531–1544) affords legal protection to 

individual animals and their habitats based on their current status and the threats those animals could face 

in the future. Species or species segments (distinct population segments [DPSs]) can be classified as 

endangered, threatened, candidate, or proposed for listing. Additional information on the environmental 

resources that could be found in the planning areas is provided in the documents listed in Section 7.2, 

which also discusses the Programmatic EIS that will be developed for this National OCS Program. The 

Programmatic EIS will include additional, more detailed analysis of the environmental setting and 

potential impacts that could arise from oil and gas leasing activities. A Programmatic EIS was completed 

for the 2017–2022 Program (BOEM 2016) and it is hereby incorporated by reference. The Programmatic 

EIS for the 2019–2024 Program will identify sensitive areas that could warrant exclusion from 

development and mitigation measures for activities within leased areas that could have environmental 

impacts. The analysis will address whether mitigation measures are appropriate at the National OCS 

Program stage or should be deferred to the leasing or plan approval stages. The Programmatic EIS will 

address cumulative effects and effects that cross BOEM planning area boundaries, such as potential 

impacts on migratory animals. 

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7.1.1 Alaska Region 

Geographic Area. The Alaska Region includes 15 planning areas that collectively fall within six Large 

Marine Ecosystems (LMEs) (see Figure 7-1). Eight of the planning areas cross the boundaries of two 

different LMEs (Beaufort Sea, Chukchi Sea, St. Mathew-Hall, Navarin Basin, Aleutian Basin, Bowers 

Basin, Aleutian Arc, and St. George Basin). For the discussion of the Alaska Region, these six LMEs 

have been combined into three BOEM ecoregions as discussed in the Environmental Sensitivity analysis 

found in Section 7.3 (see Figure 7-19). For ease of analysis, planning areas will be discussed below by 

BOEM ecoregion (Arctic, Bering Sea, and Gulf of Alaska). Table 7-1 shows planning areas per BOEM 

ecoregion. 

Figure 7-1: NOAA Large Marine Ecosystems and BOEM Alaska Planning Areas 

The three separate BOEM ecoregions within the Alaska Region are defined by geography, physical 

oceanography, and biological communities: (1) the Arctic, comprising the Beaufort and Chukchi seas; 

(2) the East Bering Sea, defined by the Bering Strait to the north and the Alaska Peninsula and Aleutian 

Islands to the south; and (3) the Gulf of Alaska, defined by mainland Alaska to the east and north and the 

Alaska Peninsula to the northwest. 

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Table 7-1: BOEM Ecoregions and Alaska Planning Areas 

Ecological Region Planning Areas 

Arctic Beaufort Sea, Chukchi Sea, Hope Basin 

Bering Sea Norton Basin, Navarin Basin, St. Matthew-Hall, Aleutian Basin, 

Bowers Basin, St. George Basin, North Aleutian Basin, Aleutian 

Arc (partial) 

Gulf of Alaska Aleutian Arc (partial), Shumagin, Kodiak, Gulf of Alaska, Cook 

Inlet 

7.1.1.1 Arctic 

Geographic Area. The Arctic OCS includes the Chukchi and Beaufort seas. The Hope Basin Planning 

Area is within the Chukchi Sea/Kotzebue Sound area. The U.S. Chukchi Sea extends from the Bering 

Strait north and east along the coast of Alaska to approximately Point Barrow, Alaska. The Beaufort Sea 

extends from approximately Point Barrow eastward along the northern coast of Alaska to Canada. The 

Chukchi and nearshore Beaufort regions are generally shallow, with a broad (100- to 300-mile [160- to 

483-km] -wide) shallow shelf in the Chukchi Sea, and a narrower (< 60 miles [96.5 km]) shelf in the 

Beaufort Sea; the shallow continental shelf drops off sharply northward to the Arctic Basin. 

Physical Oceanography. The Chukchi/Beaufort region is characterized by several unique physical and 

ecological characteristics. Seasonal pack ice moves southward into the region during the winter months 

from mid-November to mid-January. Sea ice covers the Chukchi and Beaufort Shelf for about eight or 

nine months of the year and reaches its maximum extent in March. Landfast ice (ice that forms adjacent 

to and extends from the land) begins to form in October and can extend 25 miles (40 km) or more from 

shore. The pack ice retreats during the summer, reaching its minimum extent in September. However, 

ice-diminished conditions are becoming more extensive during the summer months (ICCT 2015). 

The Chukchi Sea water flow is characterized by several distinct currents running from south to north. 

The Alaska Coastal Current brings fresh, warm water from the Bering Sea into the Chukchi Sea, and 

continues along the shelf break into the Beaufort Sea. A central Chukchi Sea Current brings nutrient-rich 

waters from the Bering Sea and Anadyr Bay into the central Chukchi Sea; this current splits around 

Herald and Hanna shoals. The Chukchi Sea is also influenced by upwellings, which occur in shelf break 

canyons. In the Beaufort Sea, waters from the Canadian Beaufort Sea enter the Alaskan Beaufort Sea 

from the east and continue along the shelf edge and northward. Arctic waters move from the northern 

Arctic Ocean and along the shelf break from northwest to southeast. The Beaufort Sea gyre, shown in 

Figure 7-2, is wind-driven and an important fresh water concentrator (Weingartner 2017). The 

Mackenzie River Delta on the Canadian Beaufort Sea also contributes to the turbidity and lower salinity 

of the Beaufort Sea region. The movement and presence of sea ice, and the extended periods of summer 

daylight and winter darkness, are dominant features of the Arctic seascape and impact the physical, 

biological, and cultural aspects of life in the area. The presence of seasonal ice contributes to low 

salinities in the region. 

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Figure 7-2: Predominant Currents in the Beaufort and Chukchi Seas 

Source: Weingartner 2017 

Ecological Features. The Arctic OCS is known for its ice-associated marine mammals. Polar bears and 

some ringed seals remain in the region year round. Many species are migratory and move southward 

through the Bering Strait in late fall ahead of the sea ice and northward and eastward through the Bering 

Strait in spring as the ice retreats. In summer, the Chukchi Sea is home to numerous mammal species, 

including Pacific walrus; ribbon, bearded, spotted, and ringed seals; killer, fin, gray, minke, and 

humpback whales; and harbor porpoise. Bowhead and beluga whales move northward through the 

Chukchi Sea and then typically continue eastward through the U.S. Beaufort Sea into the Canadian 

Beaufort Sea. The Beaufort Sea is home to ringed, spotted, and bearded seals; bowhead, beluga, and 

occasional gray whales; and harbor porpoise. Many bird species in large numbers are found on the shore 

and in the waters of the Arctic OCS, including waterfowl (e.g., eiders, long-tailed duck, swans, scoters, 

black brant, other geese), shorebirds (e.g., phalaropes, plovers, sandpipers, turnstones), and other marine 

birds (e.g., loons, fulmars, shearwaters, jaegers, gulls, murres, guillemots, puffins). The lagoons and river 

deltas along the Arctic coast, such as the Kaseguluk Lagoon area along the Chukchi Sea coast, the 

Colville River Delta, and Smith and Peard bays along the Beaufort Sea coast, are important foraging and 

molting areas for a variety and abundance of marine bird species. The Chukchi/Beaufort region provides 

habitat for 110 species of fish, such as sculpin, cod, and herring (Thorsteinson et al. 2016, Datsky2015). 

The northernmost presence of deepwater corals and Arctic kelp beds in Alaska are in the Beaufort Sea. 

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Threatened or Endangered Species. Marine species in and near the Arctic OCS that are listed under the 

ESA as threatened [t], endangered [e], or candidate [c] and could be impacted by potential oil- and 

gasrelated activities include the following: 

• Birds (2): spectacled eider [t], Steller’s eider [t]. 

• Marine mammals (8): bowhead whale [e], western north Pacific DPS of humpback whale [e], 

western North Pacific DPS of gray whale [e], fin whale [e], Beringia DPS of bearded seal [t], 

polar bear [t]. 

Critical Habitat. Designated critical habitat is shown in Figure 7-3 for Chukchi and Beaufort seas. 

Designated critical habitat for the spectacled eider is on the Chukchi Sea coast of Alaska. Designated 

critical habitat for polar bears is offshore and alongshore the Chukchi and Beaufort seas of Alaska. In 

addition, the USFWS designated important foraging areas for Pacific walrus in portions of the Hanna 

Shoal region as the Hanna Shoal Walrus Use Area (Jay et al. 2012). These areas receive additional 

protection through Marine Mammal Protection Act (MMPA) authorization restrictions. 

Figure 7-3: Beaufort Sea and Chukchi Sea Critical Habitat 

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Human Use. The State of Alaska is home to 741,894 residents as of 2016 (USCB 2016a). About 

40 percent of all federally recognized tribes have members who live throughout the state, with the 

majority residing in coastal areas (USCB 2016a). These coastal areas are populated with subsistence 

communities who depend largely on the natural environment, especially the marine environment, for food 

and materials. Each year, communities across northern Alaska participate in bowhead whale hunts that 

are central to their cultural tradition. In addition, fish (e.g. cod, herring, whitefish, Arctic cisco, Arctic 

char, and salmon), ringed seals, bearded seals, and beluga whales are all important marine subsistence 

species (ADF&G 2017a). The State of Alaska relies heavily on the following for its economy: 

Fishing Non-Consumptive Industrial 

Commercial fishing/harvesting Outdoor recreation Oil and gas production 

Hunting for marine animals Tourism (cruise ships) Shipping 

Recreational fishing Indigenous cultural/spiritual uses 

Section 6.5 includes additional information on other uses of the OCS. 

Comments Received: Numerous comments were received in response to the RFI related to potential 

environmental impacts in the Arctic associated with the National OCS Program. A summary of 

substantive comments is provided in Appendix A. In addition to comments addressing the potential 

impacts, BOEM received several nominations for exclusion of areas on the basis of their environmental or 

human use significance, including the following: 

• A coastal corridor in the Chukchi Sea Planning Area, including areas that have been excluded 

from past National OCS Programs 

• Hanna Shoal in the Chukchi Sea Planning Area 

• Herald Shoal in the Chukchi Sea Planning Area 

• The area around and including Barrow Canyon, which crosses the boundary between the 

Chukchi Sea and Beaufort Sea planning areas 

• Smith Bay in the Beaufort Sea Planning Area 

• An area including Harrison Bay and the Colville River Delta in the Beaufort Sea Planning 

Area 

• Several coastal locations important to subsistence use, including but not limited to the Barrow 

Whaling Area and Kaktovik Whaling Area that have been considered or excluded in past 

National OCS Programs 

• Portions of the waters along the shelf break in the Beaufort Sea Planning Area. 

The North Slope Borough, the Alaska Eskimo Whaling Commission, and the Arctic Slope Regional 

Corporation all requested that some or all of these areas be considered for protection during the 

development of the National OCS Program. This included requests for additional consultation, 

coordination, and engagement with local stakeholders to define appropriate areas for exclusion. 

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7.1.1.2 Bering Sea 

Geographic Area. The Alaska Peninsula separates the Bering Sea from the Gulf of Alaska to the 

southeast. The Bering Sea is bounded by Alaska to the east and northeast, Russia’s Far East and 

Kamchatka Peninsula to the west, the Aleutian Islands to the south, and the Bering Strait to the far north. 

The continental shelf in the Bering Sea is very broad, extending more than 300 miles (483 km) from shore 

at its widest extent. Water moves from the Bering Sea through the Bering Strait and into the Arctic 

Ocean via the Chukchi Sea. The planning areas within the Bering Sea ecological region include Norton 

Basin, North Aleutian Basin, St. George Basin, St. Matthew-Hall, Navarin Basin, Aleutian Basin, Bowers 

Basin, and the northern portion of the Aleutian Arc (see Table 7-1). 

Physical Oceanography. Sea ice forms throughout the Bering Sea each winter, entering in the fall and 

retreating from the region through the Bering Strait in the late winter. Circulation in the Bering Basin is 

typically described as a cyclonic gyre, bounded by the Kamchatka Current flowing southward and the 

Bering Slope Current flowing northward. Water transport is generally northward through a number of 

passes between the islands of the Aleutian chain (Stabeno et al. 1999). The Yukon River provides a large 

source of fresh water input. 

Ecological Features. The OCS waters of the Bering Sea include extensive eelgrass beds, such as those 

found in Izembek NWR in Bristol Bay, and host at least 450 species of fish, crustaceans, and mollusks; 

more than 50 species of marine birds; and 25 species of marine mammals (NRC 1996). Many of these 

species are protected, such as certain marine mammals and birds, or are commercially valuable, such as 

king crab, pollock, salmon, and cod. Species that occupy the outer shelf area and feed in the pelagic, or 

open-water, zone include seabirds, mammals, and fish that consume smaller, schooling fishes. One of the 

most important fish species is the walleye pollock, which makes up a significant portion of the total 

amount of marine life in the offshore system, and, along with other forage fish, is an important food 

source for nesting seabirds and seals. Inshore shelf waters consist more commonly of bottom-dwelling or 

bottom-associated species, such as demersal fishes and crabs, which feed primarily on organisms that live 

on or in the seafloor. 

The seasonal movement of the sea ice affects the distribution of ice-associated species within the Bering 

Sea, including fishes, walruses, and seals. Walrus, bearded seals, ringed seals, and bowhead whales move 

southward with the advancing sea ice and winter in the Bering Sea. Fish and other species benefit from 

the ice cover and increased productivity that is a result of the seasonal sea ice. Many species occur 

seasonally in the Bering Sea. Gray and fin whales occupy the Bering Sea during the summer and early 

fall. Steller sea lions and northern fur seals move north into the Bering Sea during the summer and retreat 

to the Aleutian and Pribilof Islands, or farther south, during the winter. 

The eastern Bering Sea also contains deepwater coral habitats. Deepwater corals are an important part of 

the benthic habitat in Alaska. They occur across a variety of depths (78 feet [24 m] to more than 

15,000 feet [4572 m]) and provide habitat for commercial fish and crab species (NRC 1996). Soft corals 

are common in the Bering Sea. 

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Threatened or Endangered Species. Marine species in and near the Bering Sea that are listed under the 

ESA as threatened [t], endangered [e], or candidate [c] and could be impacted by potential oil- and 

gas-related activities include the following: 

• Birds (3): Steller’s eider [t], spectacled eider [t], short-tailed albatross [e] 

• Marine mammals (12): western north Pacific [e] and Mexico [t] DPSs of humpback whale, 

fin whale [e], bowhead whale [e], sperm whale [e], blue whale [e], sei whale [e], North 

Pacific right whale [e], western north Pacific DPS of gray whale [e],western DPS of Steller 

sea lion [e], Beringia DPS of bearded seal [t], southwest Alaska DPS of northern sea otter [t] 

• Sea turtles (4 species occasionally occurring in the Bering Sea, particularly in 

El Niño-Southern Oscillation [ENSO] years): leatherback turtle [e], central north Pacific and 

east Pacific DPS of green turtle [t], North Pacific Ocean DPS of loggerhead turtle [e], olive 

Ridley sea turtle [t] 

• Fish (15 subspecies occasionally occurring in the Bering Sea): 14 subspecies of steelhead 

and salmon from the Pacific Northwest [4e and 10t], green sturgeon [t]. 

Critical Habitat. A large portion of the Bering Sea between the Seward Peninsula and the Aleutian 

Islands is designated as critical habitat (see Figure 7-4). Critical habitat for polar bears is offshore and 

alongshore the Bering Sea to southwest of Saint Lawrence Island. North of the Alaska Peninsula and 

adjacent to Bristol Bay is critical habitat for the North Pacific right whale. The majority of the Aleutian 

Islands, the Pribilof Islands, St. Matthew and St. Lawrence islands, and nearshore areas on the northern 

shore of Bristol Bay and the Aleutian Islands are designated critical habitat for the western DPS of Steller 

sea lions. Designated critical habitat for Steller’s eider is on the northern shore of the Alaska Peninsula 

and along the shore of Yukon Delta NWR. Designated critical habitat for spectacled eider is south of 

Saint Lawrence Island, in Norton Sound, and along a portion of the shore of the Yukon Delta NWR. 

Nearshore waters along the Alaska Peninsula and Aleutian Islands are designated as critical habitat for the 

southwest Alaska DPS of the northern sea otter. 

Human Use. Human coastal communities of the Bering Sea region rely on subsistence and commercial 

fishing. The Bering Sea has some of the most productive fisheries in the United States, most notably 

those for salmon, king crab, and pollock (ADF&G 2017b). Bristol Bay is an especially valuable area for 

commercial and sport fishing. Numerous freshwater nursery lakes and shallow estuaries make Bristol 

Bay the largest commercial sockeye salmon producing region in the world. Examples of human uses in 

the Bering Sea region include the following: 

Fishing Non-Consumptive 

Commercial fishing/harvesting Tourism 

Hunting for marine animals Indigenous cultural/spiritual uses 

Recreational fishing 

Other uses of the OCS are discussed in detail in Section 6.5. 

Comments Received. Numerous comments were received in response to the RFI related to potential 

environmental impacts in Alaska associated with the National OCS Program. A summary of substantive 

comments is provided in Appendix A. 

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Figure 7-4: Bering Sea Critical Habitat 

7.1.1.3 Gulf of Alaska 

Geographic Area. The Gulf of Alaska is a large, semi-circular bight bounded by the coast of mainland 

Alaska to the north and east and the Aleutian Islands to the west. It opens into—and is largely exposed 

to—the North Pacific Ocean. The Gulf of Alaska has a relatively narrow continental shelf, ranging from 

about 30 miles (48 km) off southeastern Alaska to more than 100 miles (160 km) near Kodiak Island. 

Cook Inlet is along the west-central coast of the Gulf of Alaska and bounded at the entrance by Kodiak 

and Afognak islands. The planning areas in the Gulf of Alaska include Cook Inlet, the Gulf of Alaska, 

Kodiak, Shumagin, and the southern portion of the Aleutian Arc. 

Physical Oceanography. The climate of the Gulf of Alaska is warmer than the Arctic and northern 

Bering Sea. Sea ice does not regularly occur in the open Gulf of Alaska; however, Cook Inlet, Prince 

William Sound, and Glacier Bay all have ice formations of various kinds in the winter, and nearshore ice 

forms along the Alaska Peninsula and the Aleutian Islands in some years. 

Ecological Features. The Gulf of Alaska hosts a wide variety of marine life, including as many as 

24 species of marine mammals, 247 species of birds, and at least 383 species of fish, including 5 species 

of salmon (NRC 1996). The marine mammals that occur in the Gulf of Alaska include whales, dolphins, 

seals, sea lions, and otters; some of these animals remain in this area year round, while others move 

seasonally. The offshore, nearshore, and coastal habitats of the Gulf of Alaska OCS provide feeding, 

nesting, wintering, and migratory areas for a variety of seabirds, sea ducks, and shorebirds. The fish 

assemblages of the Gulf of Alaska are extremely diverse, including both subarctic and temperate species, 

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with Arctic species favoring the western portions of the Gulf of Alaska and the temperate species 

occurring more in the eastern portions. Many commercially valuable fish species occur in the Gulf of 

Alaska, including salmon, walleye pollock, cod, and crab. 

The Gulf of Alaska and Aleutian Islands contain deepwater coral habitats. The Aleutian Islands have a 

very high diversity and abundance of deepwater corals. Deepwater corals are an important part of the 

seafloor (benthic) habitat in Alaska. They occur across a variety of depths (78 feet [24 m] to more than 

15,000 feet [4572 m]) and provide habitat for commercial fish and crab species (NRC 1996). 

Threatened or Endangered Species. Marine species in and near the Gulf of Alaska that are listed under 

the ESA as threatened [t] or endangered [e] and could be impacted by potential oil- and gas-related 

activities include the following: 

• Birds (2): Steller’s eider [t], short-tailed albatross [e] 

• Marine mammals (10): western north Pacific [e] and Mexico [t] DPSs of humpback 

whale [e], fin whale [e], sperm whale [e], blue whale [e], sei whale [e], North Pacific right 

whale [e], Cook Inlet beluga whale [e], western north Pacific DPS of gray whale [e], western 

DPS of Steller sea lion [e], southwest Alaska DPS of northern sea otter [t] 

• Sea turtles (4 species occasionally occurring in the Gulf of Alaska, particularly in ENSO 

years): leatherback turtle [e], central north Pacific and east Pacific DPS of green turtle [t], 

north Pacific Ocean DPS of loggerhead turtle [e], olive Ridley sea turtle [t] 

• Fish (15 subspecies occasionally occurring in the Gulf of Alaska): 14 subspecies of steelhead 

and salmon from the Pacific Northwest [4e and 10t], green sturgeon [t]. 

Critical Habitat. Critical habitat is designated in or adjacent to the Gulf of Alaska for North Pacific right 

whales, the Steller sea lion western DPS, Steller’s eider, the Cook Inlet beluga whale DPS, and the 

northern sea otter (see Figure 7-5). 

Human Use. Tourism consists largely of sightseeing cruise ships and eco-tourism (including glacier and 

wildlife viewing), recreational fishing (including charter boats), camping, kayaking, and hiking. Other 

uses of the OCS are discussed in detail in Section 6.5. Prominent human uses in the Gulf of Alaska 

include the following: 

Fishing Non-Consumptive 

Commercial fishing/harvesting Tourism 

Hunting for marine animals Indigenous cultural/spiritual uses 

Recreational fishing 

Comments Received. Numerous comments were received in response to the RFI related to potential 

environmental impacts in Alaska associated with the National OCS Program. A summary of substantive 

comments is provided in Appendix A. 

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Figure 7-5: Gulf of Alaska Critical Habitat 

7.1.2 Pacific Region 

Geographic Area. The Pacific Region includes four planning areas that are within one LME called the 

California Current LME and defined by the California Current System, which moves southward along the 

western coast of North America from British Columbia, Canada, to Baja, California (see Figure 7-6). The 

U.S. west coast is approximately 1,300 miles (2,090 km) long from north to south, with the coast of 

California accounting for 65 percent (about 845 miles [1360 km]) of that distance. The continental shelf 

along the U.S. west coast is generally very narrow (10 to 70 miles [16 to 113 km] wide) and drops off 

steeply at the shelf break. Offshore southern California, the area beyond the shelf break consists of a 

topographically complex region, known as the continental borderland, which includes eight islands and 

associated banks and basins. This area is defined geographically as the Southern California Bight (SCB). 

Physical Oceanography. The California Current System is a transitional zone between subarctic and 

subtropical water masses bounded by the Subarctic Current to the north and equatorial waters to the 

south. Due to the complexity of the continental borderland as noted above, the California Current System 

exhibits a northward-flowing countercurrent, eddies, and strong upwelling (Winant et al. 2006). The 

system can be affected by cyclical phenomena, such as the ENSO, which causes higher water 

temperatures and decreased upwelling within the California Current System, as well as wide swings in 

weather patterns. Under these circumstances, subtropical species often appear, returning southward when 

the normal oceanographic and weather patterns reappear. 

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Ecological Features. In part due to its transitional nature, the California Current System hosts a wide 

variety of marine mammals, seabirds, sea turtles, marine fishes, and invertebrates. Strong coastal 

upwelling brings nutrient-rich bottom waters to the surface and supports many productive fisheries, as 

well as large and diverse marine mammal and seabird populations (Aquarone and Adams 2017a). 

Subarctic species are more common in the northern portions of the region, while temperate and 

subtropical species generally are found farther south. In years with warmer water temperatures, such as 

during an ENSO event, warm-water species could venture farther north along with the warmer water. 

Coastal wetlands provide habitat for resident and migratory shorebirds and waterfowl along the entire 

Pacific coastline. Large baleen whales such as blue, fin, and gray whales; sea lion and several kinds of 

seals; seabirds such as albatrosses, gulls, and brown pelicans; and large, open-water, predatory species 

such as great white sharks are present along the entire west coast, as are Dall’s porpoise, Scoters, 

rockfish, herring, and salmon species. 

In general, many of the species listed below can be found in greater or lesser numbers across the entire 

region. Therefore the listing below is in rough order of relative commonality north to south: In the 

northern portion of the region (the Washington/Oregon and Northern California Planning Areas), bull 

kelp, killer whales, salmon, and seabirds, such as the Common Murre, are integral parts of the ecological 

and cultural setting. The central California coast includes such temperate species as the giant kelp; sea 

otters, dolphins, and porpoises; and squid, crab, rockfish, and many other fish and invertebrate species. 

The SCB represents the northernmost and southernmost limits for the distribution of equatorial and highlatitude species, respectively. The area is also important habitat for the early life stages of many 

commercially valuable fish species. The islands in the continental borderland and surrounding waters 

serve as breeding and foraging habitat for seabirds (such as Scripps’s [Xantus’s] murrelet), marine 

mammals (including northern elephant seals, California sea lions, harbor seals, northern seals, and 

Guadalupe fur seals), and many species of whales and dolphins. 

Deepwater coral habitats also exist offshore the U.S. west coast. Off of the Washington coast, coral 

communities provide habitat for many species of invertebrates and fish, including several rockfish 

species. There are records of deepwater corals both on and off the shelf from Puget Sound, Washington, 

to San Diego, California. These coral communities tend to be spread over discrete areas of suitable 

habitat and provide “islands” of habitat within larger areas of homogeneous substrate. They can occur in 

a variety of regions, including on the continental slope, in underwater canyons, or on underwater 

mountains known as seamounts. 

Numerous commercially valuable species are found along the west coast, including Pacific salmon, hake, 

albacore tuna, Pacific sardine, northern anchovy, jack mackerel, chub mackerel, Pacific herring, rockfish, 

and Pacific halibut (Aquarone and Adams 2017a). Other species with high commercial value include 

shrimp, squid, crab, clam, and abalone (Aquarone and Adams 2017a). Most fisheries stocks in the area 

experience very high fishing pressure. Fisheries also are affected by changes in the climatic regime; this 

is particularly true for schooling pelagic fishes such as sardines and anchovy. A decrease in the 

abundance of these fish stocks can affect the entire ecological system, because many larger predators, 

such as birds and marine mammals, rely on them for food. 

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USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Figure 7-6: NOAA Large Marine Ecosystems and BOEM Pacific Planning Areas 

Threatened and Endangered Species. Marine species in and near the Pacific OCS that are listed under 

the ESA as threatened [t], endangered [e], candidate [c], or proposed [p] and could be impacted by 

potential oil- and gas-related activities include: 

• Birds (6): Short-tailed Albatross [e], Hawaiian Petrel [e], Light-footed Ridgway’s Rail [e], 

Western Snowy Plover [t], Marbled Murrelet [t], and California Least Tern [e] 

• Marine mammals (9): North Pacific right whale [e], humpback whale [e], sei whale [e], 

fin whale [e], blue whale [e], sperm whale [e], Southern Resident DPS of killer whales [e], 

Guadalupe fur seal [t], southern sea otter [t] 

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• Sea turtles (4): leatherback turtle [e], green turtle [e], loggerhead turtle [t], olive ridley 

turtle [e] 

• Fish or invertebrates (12): scalloped hammerhead shark (Eastern Pacific DPS) [e], Gulf 

grouper [e], tidewater goby [e], steelhead [t/e], North American green sturgeon [t], white 

abalone [e], black abalone [e], eulachon [t], chum [t], coho salmon [t/e], sockeye salmon [t/e], 

chinook [t/e] salmon, Pacific Bluefin tuna [c], giant manta ray [pt], longfin smelt [c] 

• Amphibians (1): California red-legged frog [t] 

• Plants (1): salt marsh bird’s-beak [e]. 

Critical Habitat. Critical habitat is designated in the Pacific Region for Southern Resident DPS of killer 

whales, eastern DPS of Steller sea lion,37 leatherback sea turtle, Western Snowy Plover (Pacific Coast 

DPS), Marbled Murrelet, California red-legged frog, tidewater goby, North American green sturgeon 

(southern DPS), eulachon (southern DPS), black abalone, steelhead, and salmon within and adjacent to 

Pacific OCS waters (Figures 7-7 through 7-11). 

Human Use. The planning areas being considered for future oil and gas leasing in the Pacific OCS are 

offshore of Washington, Oregon, and California. These states are home to a population of 50.6 million 

people and include 140 federally recognized tribes and numerous historically marginalized communities 

(low-income and communities of color) (USCB 2016a). Human use of these waters is extensive and can 

be categorized into three broad sectors: fishing, non-consumptive, and industrial (NOAA 2009). Some 

examples of these uses include, but are not limited to, the following: 

Fishing Non-Consumptive Industrial 

Commercial fishing/harvesting Beach use Aquaculture 

Hunting for marine animals Boating/sailing/kayaking Cruise ships 

Recreational fishing SCUBA/snorkeling Military use 

Watersports Offshore energy 

Indigenous cultural/spiritual uses Shipping 

Wildlife viewing Marine minerals 

Dumping 

Pollution from various onshore and offshore activities contributes to water quality degradation and air 

quality exceedances above the national standards in major metropolitan areas along the coast. Other uses 

of the OCS are discussed in detail in Section 6.5. 

Comments Received. Numerous comments were received in response to the RFI related to potential 

environmental impacts in the Pacific Region associated with the National OCS Program. A summary of 

substantive comments is provided in Appendix A. In addition to comments addressing the potential 

impacts, BOEM received a nomination to exclude the Santa Barbara Channel from leasing consideration. 

All NMSs were also nominated for exclusion. In the Pacific Region, this includes the Olympic Coast, 

Cordell Bank, Greater Farallones, Monterey Bay, and Channel Islands NMSs. 

37 The eastern DPS of Steller sea lions was delisted in 2013 but designated critical habitat remains pending a NMFS rulemaking. 

This critical habitat was designated because it supports the western DPS’s important biological functions (78 FR 66140). 

Environmental Consideration Factors and Concerns 7-14 January 2018 
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Figure 7-7: Pacific Region Critical Habitat for Green Sturgeon and California Red-legged Frog 

Environmental Consideration Factors and Concerns 7-15 January 2018 
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Figure 7-8: Pacific Region Critical Habitat for Killer Whale, Marbled Murrelet, and Black Abalone 

Environmental Consideration Factors and Concerns 7-16 January 2018 
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Figure 7-9: Pacific Region Critical Habitat for Eulachon, Leatherback Sea Turtle, and Steller Sea Lion 

Environmental Consideration Factors and Concerns 7-17 January 2018 
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Figure 7-10: Pacific Region Critical Habitat for Salmon and Steelhead 

Environmental Consideration Factors and Concerns 7-18 January 2018 
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Figure 7-11: Pacific Region Critical Habitat for Western Snowy Plover and Tidewater Goby 

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7.1.3 Gulf of Mexico Region 

Geographic Area. The GOM is a semi-enclosed water body forming one LME about 950 miles 

(1,530 km) in diameter and encompassing more than 0.58 million mi2 (1.5 million km2

) (NOAA 2017a; 

Figure 7-12). The maximum depth is more than 12,000 feet (about 3,700 m) (Brooke and 

Schroeder 2007). The GOM OCS waters are only in the northern GOM. The northern GOM abuts the 

states of Texas, Louisiana, Mississippi, Alabama, and Florida. The focus of this analysis is on the OCS, 

and therefore there will be no discussion specifically on the Mexican and Cuban waters of the southern 

GOM. The GOM Region includes three BOEM planning areas: Western GOM, Central GOM, and 

Eastern GOM (see Figure 1-3). 

For this DPP analysis, BOEM divided the GOM LME (Figure 7-8) into the Western GOM ecoregion and 

the Eastern GOM ecoregion along the Eastern and Central GOM Planning Area boundary as described in 

Section 7.3 (Figure 7-20). There are geologic differences between the Eastern GOM along Florida and 

the remainder of the northern GOM (Buster and Holmes 2011). The continental shelf in the Western 

GOM is broadest (up to 135 miles [217 km]) off Houston, Texas, and east to offshore the Atchafalaya 

Delta, Louisiana. It reaches its narrowest point (less than 10 mi [16 km]) near the mouth of the 

Mississippi River southeast of New Orleans, Louisiana. The continental shelf is narrow offshore Mobile 

Bay, Alabama, but broadens significantly offshore Florida to almost 200 mi (322 km) wide (Brooke and 

Schroeder 2007). 

Figure 7-12: NOAA Large Marine Ecosystem and BOEM Gulf of Mexico Planning Areas 

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Physical Oceanography. The GOM is tropical to subtropical and receives salt water inputs from the 

Yucatán Channel and fresh water from large riverine systems (e.g., Mississippi River) of the United 

States and Mexico. Tidal range is small, usually less than two feet (0.6 m), and three major, persistent 

currents exist in the GOM. The most dominant is the Loop Current (Sturges et al. 2005) that flows 

clockwise into the GOM between Cuba and the Yucatán Peninsula, Mexico, and circulates into the 

Eastern GOM before exiting the GOM through the Straits of Florida, where it ultimately joins the Gulf 

Stream in the Atlantic Ocean. Smaller-scale, ephemeral currents known as eddies form off the Loop 

Current and can enter the western GOM. The GOM also experiences freshwater input from several 

rivers, most importantly the Mississippi River, which drains about 40 percent of the continental United 

States (Mitsch et al. 2001) and carries large amounts of sediment and a variety of nutrients and pollutants. 

The highest volume of freshwater flow from the Mississippi River into the GOM occurs during late 

winter into early summer and can reduce salinities considerably for dozens of miles offshore. 

Ecological Features. In the entire GOM, more than 15,000 species from more than 40 phyla have been 

documented (Felder et al. 2009). The northern GOM supports several important commercial fisheries, 

including grouper, shrimp, menhaden, mullet, snapper, lobster, blue crab, and oyster (NMFS 2017b), each 

with more than 5 million pounds annually harvested. The GOM is also home to a diverse set of 

ecosystems, including coral reefs, mangroves, barrier islands, wetlands, oyster beds, and topographic 

features, such as corals and deepwater seeps. 

Although the Eastern and Western GOM ecoregions share similar habitat and species assemblages, there 

are some key differences. The Western GOM ecoregion contains the Flower Garden Banks NMS, the 

only sanctuary site in the Western GOM. The Florida Keys NMS lies just to the southeast of the Eastern 

GOM (NOAA 2017b). The outer edge of the Western GOM continental shelf is dotted with numerous 

topographic features. Each region hosts distinct shrimp populations; brown and white shrimp are more 

abundant in the Western GOM, and pink shrimp are more abundant in the Eastern GOM (NOAA 2017a). 

The Western GOM contains the most nesting sites for the endangered Kemp’s ridley sea turtle, whereas 

the nesting sites for loggerhead (threatened) sea turtles occur predominantly in the Eastern GOM 

(NOAA 2016). There are two species of large whale that occur in the GOM: Bryde’s whale, and a 

resident population of sperm whale in the north-central GOM. The Eastern GOM includes most of the 

habitat for the threatened manatee, whose U.S. range is primarily centered in the bays, sounds, and 

estuaries of Florida, but can extend into Texas (USFWS 2013, Cornish 2015). 

The GOM is part of three major migratory bird paths, known as flyways (Atlantic, Mississippi, and 

Central). The GOM provides wetland, nearshore, and offshore habitats for songbirds, seabirds, 

shorebirds, waterfowl, sea ducks, and wading birds. The Mississippi River Delta, along with its coastal 

wetlands and barrier islands, is one of the most productive and vulnerable regions of the Gulf coast. This 

vast natural asset supports thriving shipping, energy, seafood, and recreation industries while providing 

extensive coastal habitats for more than 400 bird species (USFWS 2013). There are several Fishery 

Management Plans and amendments for the GOM that include: aquaculture, coastal migratory pelagic 

fish (mackerels and cobia), coral reefs, red drum, reef fish (snappers, groupers, tilefishes, jacks, 

triggerfishes, and wrasses), shrimp (brown, white, pink, and red), spiny lobster, and stone crab 

(GOMFMC 2017). Each of the plans except the plan for aquaculture includes an amendment identifying 

the locations of Essential Fish Habitat for 26 representative species (those that result in most of the 

landings from the GOM). 

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The Western GOM hosts the northernmost tropical coral reef system in the United States at the Flower 

Garden Banks NMS, an isolated system of predominantly encrusting corals atop salt dome formations. 

This system attracts reef fishes and large open-water species, such as whale sharks, and predatory fishes 

such as hammerhead sharks, jacks, cobias, and rays (NOAA 2017c). Deepwater corals also are in the 

GOM. Some of the most common deepwater coral genera include Lophelia pertusa, Madrepora oculata, 

Leiopathes sp., and Callogorgia spp. (NOAA 2013, Brooke and Schroeder 2007). Lophelia communities 

are scattered along the shelf break and upper continental slope in water depths ranging from 980 feet 

[299 m] to more than 1,600 feet [488 m]. Oculina has been documented on oil rigs off the Mississippi 

Delta (Sammarco 2014). Similar to other areas, deepwater coral communities provide important habitat 

for many species of invertebrates and fish. 

Threatened and Endangered Species. Marine species in and near the GOM OCS that are listed under 

the ESA as threatened [t], endangered [e], or proposed [p] and could be impacted by potential oil- and 

gas-related activities include: 

• Birds (8): Cape Sable seaside sparrow [e], least tern [e], Piping plover [t], Whooping crane 

[e], Mississippi sandhill crane [e], Rufa red knot [t], roseate tern [t] , Wood stork [t] 

• Marine mammals (2): sperm whale [e], West Indian manatee [t], Bryde’s whale [p] 

• Other mammals (6): Alabama beach mouse [e], Choctawhatchee beach mouse [e], Perdido 

Key beach mouse [e], St. Andrew beach mouse [e ], Florida bonneted bat [e], Florida salt 

march vole [e] 

• Sea turtles (5): leatherback turtle [e], green turtle [e/t], hawksbill turtle [e], Kemp’s ridley 

turtle [e], loggerhead turtle [t] 

• Other reptiles (1): American crocodile [t] 

• Fish (3): Gulf sturgeon [t], Nassau grouper [t], smalltooth sawfish [e] 

• Corals (6): elkhorn [t], rough cactus [t], staghorn [t], lobed star [t], mountainous star [t], 

boulder star [t]. 

Critical Habitat. Of the above-mentioned species, critical habitat is designated in the GOM for 

loggerhead turtles, Gulf sturgeon, all beach mice, West Indian manatee, Cape Sable seaside sparrow, 

piping plover, whooping crane, Mississippi sandhill crane, and elkhorn and staghorn corals. Figures 7-

13 

and 7-14 show locations of GOM critical habitat. 

Environmental Consideration Factors and Concerns 7-22 January 2018 
 

 

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Figure 7-13: Gulf of Mexico Critical Habitat for Mississippi Sandhill Crane, Piping Plover, Whooping 

Crane, Florida Manatee, and Elkhorn and Staghorn Coral 

Figure 7-14: Gulf of Mexico Critical Habitat for Gulf Sturgeon, Beach Mice, and Loggerhead Sea Turtle 

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Human Use. The GOM Region is home to more than 61 million people (USCB 2016b), including nine 

federally recognized tribes and four federally recognized tribes with historical ties to the area, now 

relocated to Oklahoma. There are numerous coastal communities in this region, some of which are 

historically marginalized communities (low-income and communities of color). This region has diverse 

natural and developed landscapes and seascapes, beaches, barrier islands, estuarine bays and sounds, river 

deltas, tidal marshes, publicly owned and administered areas (i.e., NSs, NPs, beaches, and wildlife lands), 

designated preservation areas (i.e., historic and natural sites and landmarks, wilderness areas, wildlife 

sanctuaries, and scenic rivers), and private recreational facilities and establishments that attract residents 

and visitors (i.e., resorts, marinas, amusement parks, and ornamental gardens). Ocean uses are major 

factors in the local economy of this region and include the following: 

Fishing Non-Consumptive Industrial 

Commercial fishing/harvesting Tourism Oil and gas production 

Subsistence fishing Recreation Military use 

Recreational fishing Shipping 

Onshore and offshore human use can contribute to changes in habitat, water quality, and air quality. 

Sea level rise, nutrient pollution, chemical contaminants, and urbanization are listed as top issues 

impacting the GOM (Watson et al. 2017, NOAA 2011). See Section 6.5 for additional information on 

other uses of the OCS. 

Comments Received. Numerous comments were received in response to the RFI related to potential 

environmental impacts in the GOM associated with the National OCS Program. A summary of 

substantive comments is provided in Appendix A. In addition to comments addressing the potential 

impacts, BOEM received several nominations for exclusion of areas on the basis of their environmental or 

human use significance, including the following: 

• Areas in the GOM lying south of 26 degrees North latitude, including Florida’s Marco Island 

and the Ten Thousand Islands 

• Exclusion areas designated Habitat Areas of Particular Concern under the 

Magnusson-Stevens Fishery Conservation and Management Act 

• Exclusion of areas designated as critical habitat under the ESA 

• All NMSs; in the GOM Region, these include the Flower Garden Banks and Florida Keys 

NMSs. 

7.1.4 Atlantic Region 

Geographic Area. Atlantic OCS waters stretch from the U.S.-Canada border in the north to southern 

Florida. The Atlantic Region includes the North Atlantic, Mid-Atlantic, South Atlantic, and Straits of 

Florida planning areas (see Figure 1-3). Two distinct LMEs exist along the U.S. Atlantic OCS: the 

Northeast Continental Shelf LME (Northeast LME) and the Southeast Continental Shelf LME (Southeast 

LME) (Figure 7-15; Aquarone and Adams 2017b, Aquarone 2017). The Northeast LME extends from the 

U.S.-Canada border to Cape Hatteras, North Carolina, and includes the North Atlantic Planning Area and 

approximately one-third of the Mid-Atlantic Planning Area. The Southeast LME extends from Cape 

Hatteras to southern Florida and includes the southern two-thirds of the Mid-Atlantic, South Atlantic, and 

Environmental Consideration Factors and Concerns 7-24 January 2018 
 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Straits of Florida planning areas. These LMEs can be divided into the following subregions: the 

northeastern U.S., which extends north of Cape Cod, Massachusetts; the MidAtlantic Bight (MAB), 

which extends from Cape Cod to Cape Hatteras, North Carolina; and the South Atlantic Bight (SAB), 

which extends from Cape Hatteras to Cape Canaveral, Florida. 

Figure 7-15: NOAA Large Marine Ecosystems and BOEM Atlantic Planning Areas 

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The continental shelf of the U.S. Atlantic seaboard ranges significantly in width. In the North Atlantic 

Planning Area, the shelf extends out approximately 250 miles (402 km) into the Gulf of Maine and 

narrows to less than 80 miles (129 km) off Cape May, New Jersey. From there, the shelf narrows to its 

minimum extent of approximately 20 miles (32 km) wide off Cape Hatteras, North Carolina, before 

broadening again in the South Atlantic Planning Area. The U.S. Atlantic continental shelf reaches its 

maximum extent of approximately 280 miles (450 km) wide offshore southern Georgia. These physical 

characteristics contribute to associated variability in substrate type and distribution of marine mammals, 

sea turtles, birds, fish, invertebrates, and habitats from north to south along the U.S. Atlantic coast. 

Physical Oceanography. The division between the Northeast LME and Southeast LME is based on 

physical oceanographic distinctions, with the primary feature being the two major surface currents of the 

western Atlantic Ocean: the Gulf Stream and the Labrador Current. The Gulf Stream is a warm-water 

current that flows northward along the east coast of Florida; it is the dominant feature of the Southeast 

LME. The Gulf Stream then continues parallel to the southeastern coast of the United States. It comes 

nearest to the U.S. Atlantic coast just offshore Cape Hatteras, North Carolina. From there, it turns 

northeast and flows into the central North Atlantic. The Gulf Stream is a dynamic area of higher 

productivity, and it has a strong influence on the distribution of species off the Mid-Atlantic coast. In the 

northwestern Atlantic, the colder Labrador Current flows southward from the Labrador Sea along the 

Canadian coast and influences the physical oceanography of the Northeast LME (Wilkinson et al. 2009). 

Ecological Features. Marine mammals are common throughout the Atlantic OCS waters in all planning 

areas. There are 39 species of marine mammals that could occur within the northwestern Atlantic Ocean: 

7 species of baleen whale, 27 species of toothed whales and dolphins, 4 species of seals, and the Florida 

subspecies of the West Indian manatee (Florida manatee) (BOEM 2016). All species of marine mammals 

are protected under the MMPA, and some are afforded additional protection under the ESA. A large 

number of individuals of certain species, such as the North Atlantic right whale and humpback whale, 

undergo well-defined seasonal migrations from northern to southern latitudes along the U.S. Atlantic 

coast, although not all individuals undertake these migrations. Likewise, many marine species change 

habitats during different seasons, on both a small and large scale, so species composition of a given area 

could vary by season. Beaked whales are almost always encountered in very deep waters along the shelf 

break, whereas species like the fin and minke whales could be encountered on the shelf as well as along 

the shelf break. In addition to cetaceans like whales and dolphins, marine mammals in the Atlantic OCS 

waters include rare occurrences of wide-ranging ice seal species (e.g., harp and ringed seals). Harbor 

seals and gray seals are regular inhabitants of the U.S. Atlantic coast and make seasonal movements along 

the U.S. North and Mid-Atlantic coasts. Although the majority of the marine mammal species that could 

occur in the Atlantic OCS can be found in most or all of the planning areas, some species occur mainly in 

the northern portions of the OCS (e.g., white-sided dolphins and seals) or mainly in the southern portions 

of the OCS (e.g., Florida manatee and Fraser’s dolphin). 

Five species of sea turtles can occur within the Atlantic Region, including representatives of two 

taxonomic families: Cheloniidae (loggerhead, green, hawksbill, and Kemp’s ridley turtles) and 

Dermochelyidae (leatherback turtle) (NMFS 2017a). The loggerhead turtle is the most common sea turtle 

species within the Atlantic OCS. Loggerhead sea turtles occur year round in ocean waters off North 

Carolina, South Carolina, Georgia, and Florida. As coastal water temperatures warm in the spring, 

loggerhead turtles move up the U.S. Atlantic coast as far north as the Gulf of Maine (Shoop and 

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Kenney 1992; Epperly et al. 1995a, 1995b, 1995c; Braun-McNeill and Epperly 2004). The trend is 

reversed in the fall as water temperatures cool. 

In the western North Atlantic, green turtles can be found feeding or swimming in nearshore or offshore 

waters from Florida to Massachusetts. They make seasonal movements similar to the loggerhead turtles, 

moving north with warmer waters in the summer and back south as waters cool into the winter. 

Hawksbill turtles can be found from Florida to Massachusetts, but they are rarely reported north of 

Florida. Kemp’s ridley turtles are occasionally sighted along the Atlantic coast from Florida to New 

England (NMFS et al. 2010). The MAB is an important foraging area for juvenile Kemp’s ridley turtles 

during spring through fall. Leatherback turtles are found primarily in deep waters over the shelf break, 

but also occur on the shelf and in coastal areas. They are found throughout the Atlantic OCS waters, 

depending on the season. 

Numerous marine and coastal bird species are present throughout Atlantic OCS waters, including resident 

and migratory species (Robinson Willmott et al. 2013). These include nearshore species, pelagic species, 

and gulls/gannets (Kinlan et al. 2016). Pelagic species tend to search for and feed on prey in the open 

water. Many of the pelagic species occur within and along the edges of the Gulf Stream. Nearshore 

species might include waterfowl or shorebirds. Some of these species, such as the tufted and long-tailed 

ducks, typically form large flocks and rest in large groups on the sea surface. Other nearshore species, 

including sandpipers, plovers, and stilts, utilize coastal environments for nesting, feeding, and resting. 

Many bird species, including the northern gannet, red knot, and scoters, make long-range seasonal 

movements. Birds that tend to use predominantly terrestrial habitats (e.g., passerines, falcons) might also 

occur occasionally offshore. 

Fish and invertebrate species are distributed throughout the Atlantic OCS. The Atlantic OCS supports 

approximately 700 fish species and more than 2,000 species of benthic organisms. The general diversity 

of species increases as latitude decreases; however, fish biomass decreases from north to south along the 

Atlantic OCS (Northeast Ocean Data 2016, 2017). There are commercially valuable fisheries for bottom 

and open-water fishes and invertebrates throughout Atlantic waters, including lobster; scallop; schooling 

fishes such as menhaden and herring, tunas, snapper, and grouper; flounder; rockfish; dolphin (mahimahi); billfish; and sharks. The Southeast LME supports commercial fisheries, including shrimp, herring, 

sardines, anchovies, blue crabs, and oysters (NMFS 2009, NOAA 2014). The Northeast LME is a highly 

productive, temperate area. It supports a number of commercial fisheries, including groundfish, flounder, 

mackerel, herring, haddock, lobster, and scallop. Saltwater recreational fishing targets a variety of fish 

species throughout the Atlantic Region, but is particularly important in the South Atlantic (NMFS 2017b). 

In the Northeast LME, soft bottom habitat is distributed throughout the continental shelf; the seafloor 

consists predominantly of soft sediments, mostly sands, but grading to silt and clay in deeper areas. 

Hard bottom habitats are distributed sparsely over the northeastern shelf and into the Mid-Atlantic and are 

composed of bare rock, gravel, shell hash, and artificial reefs. Hard bottom includes “live” bottom 

habitat, which includes a variety of invertebrates that are fastened to rock or other bare areas of the 

seafloor. Extensive areas of live bottom are on the southeastern U.S. continental shelf. On the shelf 

break, hard bottom habitats are associated with canyon walls that incise the shelf. Deepwater corals occur 

in many areas of the Atlantic OCS, particularly the South Atlantic and Straits of Florida planning areas. 

The coastal habitats of the Atlantic coast include rocky shores, sandy beaches, and tidal marshes. The 

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South Atlantic and Straits of Florida planning areas also include areas of coral reef habitat, including 

threatened and endangered coral species. These occur primarily in coastal, shallow waters and are more 

widespread in the Straits of Florida Planning Area and adjacent areas of coastal Florida. 

Threatened and Endangered Species. Marine species in and near the Atlantic OCS that are listed under 

the ESA as threatened [t], endangered [e], candidate [c], or proposed [p] and could be impacted by 

potential oil- and gas-related activities include: 

• Birds (5): piping plover [t], roseate tern [t/e], Bermuda petrel [e], red knot [t], wood stork [t] 

• Marine mammals (7): North Atlantic right whale [e], blue whale [e], fin whale [e], sei whale 

[e], sperm whale [e], Florida manatee [t] 

• Sea turtles (5): leatherback [e], loggerhead [t], Kemp’s ridley [e], hawksbill [e], green [e] 

• Fish (1): cusk [c], giant manta ray [p], oceanic whitetip [p] 

• Corals (7): elkhorn [t], staghorn [t], Mycetophyllia ferox [t], Dendrogyra cylindrus [t], three 

species of Orbicella star corals [t] 

• Plants (1): Johnson’s seagrass [t]. 

Critical Habitat. Designated critical habitat exists in the Atlantic OCS for the North Atlantic right whale 

and loggerhead sea turtle, in waters adjacent to the OCS for elkhorn and staghorn coral and Johnson’s 

seagrass, in inland waters of Florida for the Florida manatee, and on land for loggerhead turtles (nesting) 

and for piping plovers. Figures 7-16 and 7-17 show critical habitat for the Atlantic Region. 

Human Use. Coastal states of the Atlantic are home to 104.8 million people as of 2016 (USCB 2016c), 

including 22 federally recognized tribes, and 33 federally recognized tribes with historical ties to the area, 

now relocated to the interior of the United States. There are numerous coastal communities, some of 

which have been historically marginalized (low-income and communities of color) in this region. This 

region has a diverse set of marine and coastal industry sectors, including the following: 

Construction Energy & Minerals Ship & Boat Building 

Marine-related construction Renewable energy Boat building and repair 

Sand and gravel mining Ship building and repair 

Living Resources Tourism & Recreation Transportation 

Fish hatcheries/mariculture/ Amusement & recreation services Deep sea freight 

aquaculture Boat dealers Marine passenger transportation 

Fishing Dining Marine transportation services 

Seafood markets Hotels and lodging Search & navigation equipment 

Seafood processing Marinas Warehousing 

RV parks & campgrounds 

Scenic water tours 

Zoos/aquaria 

Environmental Consideration Factors and Concerns 7-28 January 2018 
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Figure 7-16: Atlantic Region Critical Habitat for Coral, Seagrass, North Atlantic Right Whale, 

and Piping Plover 

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Figure 7-17: Atlantic Region Critical Habitat for Manatee and Loggerhead Turtles 

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Comments Received. Numerous comments were received in response to the RFI related to potential 

environmental impacts in the Atlantic associated with the National OCS Program. A summary of 

substantive comments is provided in Appendix A. In addition to comments addressing the potential 

impacts, BOEM received several comments addressing the significance of the marine canyons in the 

Atlantic Ocean. This included a comment from the New England Fishery Management Council 

supporting withdrawal of the canyons from leasing consideration. BOEM also received nominations to 

exclude all NMSs and Marine National Monuments; in the Atlantic Region, these include the Stellwagen 

Bank, Monitor, and Gray’s Reef NMSs and the Northeast Canyons and Seamounts Marine National 

Monument. 

7.2 POTENTIAL IMPACTS ON ENVIRONMENTAL RESOURCES 

A brief discussion of the general IPFs (stressors) and possible impacts that could result from OCS oil and 

gas activities is provided in this section. These stressors have the potential to affect the environmental 

resources (receptors) discussed in Section 7.1. These impacts could be significant, but their severity 

depends upon numerous factors, including the stressor, receptor, region, time of year, mobility and/or 

resiliency of the resource, and presence of stressors in a given region unassociated with OCS oil and gas 

activities (e.g., commercial shipping, fishing). Table 7-2 provides a synopsis of the overlap between 

stressors and receptors in space and time. The relationship between stressors and the potential for impact 

on the receptors is the same for each of the four OCS regions. However, the scale and severity of these 

potential impacts might vary from region to region. The recently completed 2017–2022 Programmatic 

EIS also provides detailed information on these relationships and the severity of potential impact 

(BOEM 2016). 

Inclusion of an area under consideration for potential oil and gas activity in the 2019–2024 Program does 

not mean that activities would occur in that region or that impacts would result. However, this analysis is 

meant to identify and disclose the potential for impacts should a region be included and should activities 

occur in that area after the subsequent lease sale is held and site-specific analyses are conducted. In 

addition to oil and gas activities, environmental impacts could occur from other activities on the OCS, 

including the placement of renewable energy structures or the transport of internationally sourced oil and 

gas via tanker to U.S. ports. The decision to lease under the 2019–2024 Program also does not alter 

existing oil and gas activities on the OCS or the possible environmental impacts from those activities. 

Environmental Consideration Factors and Concerns 7-31 January 2018 
 

 

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Table 7-2: Potential for Program Activity Stressors to Impact Environmental Resource Receptors 

Program Oil & Gas 

Activity Stressors →

Environmental 

Resource 

Receptors ↓

Noise 

Vessel or 

Vehicle 

Traffic 

Drilling 

Debris & 

Discharge 

Habitat 

Disturbance 

Air 

Emissions Explosives Infrastructure 

& Lighting 

Space-use 

Conflict 

Accidental 

Spills 

Air Quality ■ ■ ■

Water Quality ■ ■ ■ ■ ■

Human Uses/ 

Archaeological Resources 

■ ■ ■ ■ ■ ■ ■ ■ ■

Fish & Fisheries ■ ■ ■ ■ ■ ■ ■ ■

Coastal and Estuarine 

Habitats 

■ ■ ■ ■

Marine Benthic Habitats ■ ■ ■ ■

Marine Pelagic Habitats ■ ■ ■ ■ ■

Invertebrates ■ ■ ■ ■ ■ ■

Marine Mammals ■ ■ ■ ■ ■ ■

Birds ■ ■ ■ ■ ■ ■ ■

Sea Turtles ■ ■ ■ ■ ■ ■ ■

Terrestrial Wildlife 

(Alaska) 

■ ■ ■ ■ ■

Key: ■ = potential for impact based on potential levels of activity, population, and receptor sensitivity.

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The potential for impacts varies depending on the region, planning area, or locations within planning 

areas. Impacts could be realized in several ways. There could be a direct physical result, such as drilling 

a hole in the seafloor or a vessel striking a sea turtle. There could be indirect physical results, such as 

changes over time in the composition of habitats on the seafloor due to pipeline emplacement, changes in 

animal behavior, or changes in the availability of food sources. Some of the potential impacts are not 

easily detected; these can include changes in animal behavior, such as avoidance of an area because of 

noise or other disturbance, or decreased reproductive capacity within a population. Some impacts occur 

immediately (e.g., injury) while others could manifest long after a receptor is exposed to a stressor 

(e.g., decreased reproductive capacity). Impacts also could vary depending on the existing environment. 

For example, the GOM has high levels of existing oil and gas activity from leases issued under previous 

National OCS Programs. Living organisms and habitats in this area are exposed to multiple stressors, 

including oil and gas development, and have been for many years. The ability of these communities to 

cope with a continued stressor could be reduced or increased by the presence of existing or multiple 

(cumulative) stressors. 

The consideration of stressors and associated potential impacts must also include consideration of the 

potential severity of impact. The Programmatic EIS that will be prepared in association with the 

development of the 2019–2024 Program will evaluate and disclose impacts in more detail and will 

identify impacts that could be significant. The subsequent NEPA analyses prepared for the lease sales 

will identify and assess impacts on a more site-specific basis. 

Impacts could be more evident where there is a higher coastal population density. Air emissions are more 

likely to be of concern where greater numbers of people could be affected by reduced air quality, as well 

as where the higher population density contributes to diminished air quality due to the presence of 

emission sources not related to oil and gas activities. The level of impacts depends also on the level of 

activities proposed for any given planning area under the National OCS Program. In areas such as the 

GOM Region, the significant magnitude of ongoing OCS oil and gas activities means that the impacts 

from the 2019–2024 Program could contribute less to the overall level of impacts from oil and gas 

activities than in areas such as the Atlantic planning areas, where oil and gas drilling has not occurred 

since 1982. Additionally, the U.S. west coast has relatively low levels of oil and gas activities with no 

new leasing since 1984. However, the Atlantic and Pacific areas have very high levels of human use in 

other areas that could result in impacts, including maritime traffic, commercial fisheries, and recreational 

activities. In the Arctic offshore Alaska, little OCS oil and gas activity is ongoing and very little 

recreational fishing or beach visitation occurs. Local communities partake in subsistence fishing and 

hunting in the area, so oil and gas activities could impact these pursuits. 

In addition to the level of activity, the impacts of oil and gas activities from the 2019–2024 Program 

depend largely on the type of stressor and the presence and sensitivity of receptors. For example, an 

accidental oil spill has the potential to impact all present receptors, regardless of geographic location. 

Vessel traffic could impact water quality through wastewater discharge, marine mammals and sea turtles 

through noise disturbance or vessel strike, and human use through space-use conflict. Some impacts, 

such as noise, might only impact those receptors that are sensitive to noise in a certain frequency range. 

The physical impact of drilling activities might affect only the receptors that are present on the seafloor, 

such as in benthic habitats. Some stressors might affect only one receptor, whereas others could have 

more widespread impacts. Furthermore, the immediate impact on a receptor from a stressor could have 

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subsequent, or cascading, impacts on other portions of the environment. For example, an impact that 

affects the abundance of schooling fishes could also affect the industries and animals that depend upon 

those schooling fishes. 

Numerous comments were received in response to the RFI related to potential environmental impacts 

associated with the National OCS Program, including the risk of oil spills, impacts on biological 

resources, and impacts on human uses of the coast and OCS waters. Summaries of substantive comments 

received are provided in Appendix A. The Programmatic EIS for the National OCS Program will include 

a description of the physical, biological, and sociocultural resources that might be affected by activities 

from the National OCS Program, as well as a discussion of the potential impacts that might occur. 

7.2.1 Accidental Oil Spills 

Oil spills are accidental and unauthorized events. Industry practices and government regulations 

minimize the frequency of these spills, and industry and government entities are prepared to respond or 

prevent spills from reaching the coast should a spill occur. Despite these efforts, there is no way to 

guarantee that oil spills will not occur. Impact analyses of accidental oil spills consider events that are 

statistically expected to occur (expected accidental small (≥ 1 to < 1,000 bbl) and large (≥ 1,000 bbl)

spills), as well as those that are statistically unexpected to occur but would still be possible (catastrophic 

discharge events [CDEs]). Expected (i.e., occurring with regular frequency) accidental events include 

spills estimated to occur during routine operations (e.g., refined, crude, or condensate spills of varying 

size from a platform, pipeline, service vessel, barge, or tanker). 

7.2.1.1 Accidental Small (≥ 1 to < 1,000 bbl) and Large (≥ 1,000 bbl) Spills 

Accidental, small, and large spills could result from OCS exploration, development, or production 

operations involving drilling rigs, production facilities, barges, tankers, pipelines, and/or support vessels. 

BOEM estimates the source and number of accidental spills (small and large) based on the estimated 

volume of oil production for each planning area along with the assumed mode of transportation 

(Anderson et al. 2012, ABS 2016). Spills from platforms are assumed to occur within or adjacent to the 

planning areas. Spills from pipelines are assumed to occur along their respective routes from production 

platform to destination. 

Historical OCS spill data provide the most relevant basis for use in analyzing the likelihood of future oil 

spills on a programmatic level. BOEM’s analyses, which currently rely on an aggregated characterization 

of historical data (where available), provide a conservative outcome when compared to other methods 

such as quantitative risk assessment. 

7.2.1.2 Catastrophic Discharge Events 

Statistically unexpected, a CDE is an event that results in a very large discharge of oil (typically greater 

than one million barrels) into the environment and could cause long-term and widespread effects on 

marine and coastal environments. The National Oil and Hazardous Substances Pollution Contingency 

Plan defines such a CDE as a “spill of national significance,” or one that “due to its severity, size, 

location, actual or potential impact on the public health and welfare or the environment, or the necessary 

response effort, is so complex that it requires extraordinary coordination of Federal, state, local, and 

responsible party resources to contain and clean up the discharge” (40 CFR 300). A catastrophic spill is 

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not expected, and would be considered well outside the normal range of probability, despite the inherent 

risks of oil exploration, development, or production-related activities expected from the 

2019–2024 Program. 

Incidents with the greatest potential for catastrophic consequences are likely to be losses of well control 

where primary and secondary barriers fail, wells do not bridge (when the wellbore collapses and seals the 

flow path), and discharge is of long duration and/or occurs in an environmentally sensitive area and/or at 

a sensitive time. However, very few loss of well control events actually lead to a CDE. A majority of the 

loss of well control events do not involve oil release and, if any oil is released, it is usually < 10 bbl. In 

addition, recently implemented safeguards, including increased requirements for the design, manufacture, 

repair, testing, and maintenance of blowout preventers, required downhole mechanical barriers, increased 

well design and testing requirements, and additional regulatory oversight make such an event even less 

likely than in the past. 

Although a CDE is not expected to result from activities associated with the 2019–2024 Program, the 

consequences of a low-probability incident, if it were to occur, could be catastrophic. Past oil spills that 

are considered relevant include the Exxon Valdez oil spill (262,000 bbl) in the Prince William Sound in 

south-central Alaska; the Ixtoc oil spill (3,500,000 bbl) in the GOM offshore Bahia de Campeche, 

Mexico; and the Deepwater Horizon event that occurred on the OCS in 2010 in the northern GOM 

(4,900,000 bbl; 800,000 bbl captured) (McNutt et al. 2011). The Exxon Valdez and Ixtoc oil spills were 

not expressly related to OCS activities. 

BSEE defines a loss of well control as: (1) uncontrolled flow of formation or other fluids to an exposed 

formation (an underground blowout) or at the surface (a surface blowout); (2) flow through a diverter; or 

(3) uncontrolled flow resulting from a failure of surface equipment or procedures. Table 7-3 provides a 

quantitative, aggregated characterization of the frequency of loss of well control resulting in oil spills in 

broad OCS regions between 1964 and 2015. 

Table 7-3: Number of Wells Compared to Loss of Well Control Events per OCS Region (1964–2015) 

Region 

Exploration Development Loss of Well 

Control 

Loss of Well Control 

with Oil Released 

Number of Wells/Boreholes Number of Events 

Alaska 84 6 0 0 

Pacific 324 1,372 5 2 

GOM 16,889 29,733 311 68 

Atlantic 51 0 0 0 

Total 17,348 31,111 316 70 

Note: BSEE requires that all loss of well control incidents be reported immediately per 30 CFR § 250.188(a)(3). 

A quantitative approach has been developed to demonstrate the relative unlikelihood of these low to very 

low probability spill incidents, wherein spill size is one of many factors that could determine the severity 

of effects (BOEM 2012). First, BOEM defined a reasonable range of potentially catastrophic OCS spill 

sizes by applying extreme value statistics to historical OCS spill data (Ji et al. 2014). Then, extreme 

value statistical methods and complementary risk assessment methods (Bercha Group 2014) were used to 

characterize the potential frequency of different size spills. 

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Table 7-4 presents BOEM’s estimates of the following elements for CDEs: 

4. Spill size return levels (i.e., the spill size that occurs with a certain frequency, or alternatively, the 

spill size that is expected to be exceeded by the annual maximum in a particular year with a given 

probability) 

5. Spill size return periods (i.e., the OCS-wide spill recurrence interval corresponding to certain 

sizes) 

6. A per-well probability that an OCS spill would exceed given sizes. 

The estimated per-well frequency for a given spill size assumes a spill occurs following loss of well 

control. The per-well spill size frequency estimates consider OCS-wide loss of well control data from 

1964 through 2015 and corresponding OCS-wide well exposure data (only original well boreholes and 

sidetracks are summed to determine well exposure; bypasses are excluded) (Table 7-4). 

Table 7-4: Annual Maximum OCS Spill Sizes for all Ongoing OCS Activities 

and OCS Planning Areas Combined 

Spill Size (bbl) 

(rounded to nearest 

thousand) 

Percent Spills Expected 

to be Less than or Equal 

to Given Spill Size 

Return Period 

(years) 

Frequency 

(per well) 

150,000 97.4 39 0.0000564 

500,000 98.8 86 0.0000422 

1,000,000 99.3 139 0.0000357 

2,000,000 99.6 229 0.0000302 

5,000,000 99.8 451 0.0000242 

10,000,000 99.87 770 0.0000205 

Note: Only original well boreholes and sidetracks are summed to determine well exposure; bypasses are excluded. 

Extreme value results show that 90 percent of any “annual maximum” oil spills are expected to be less 

than approximately16,000 bbl; 95 percent of any “annual maximum” oil spills are expected to be less than 

approximately 50,000 bbl (BOEM 2016). Spill sizes corresponding to a range of larger sizes and 

statistically useful benchmarks were also considered. These results are useful for Programmatic EIS oil 

spill analyses on exploration, development, and production, as well as oil spill response planning. 

The magnitude and severity of impacts from a CDE spill on any resource would depend on the spill type 

(oil and gas composition), location, size, depth, and duration as well as the spill source (e.g., loss of well 

control, pipeline, or vessel), meteorological conditions such as wind speed and direction, seasonal and 

environmental conditions, physiography of the spill area, biota in the area, previous exposure of the area 

to oil, and the effectiveness of response activities. The meteorological and environmental conditions can 

have a substantial effect on weathering processes such as evaporation, emulsification, dispersion, 

dissolution, microbial degradation and oxidation, and transport of the spilled products. The uncontrolled 

oil and/or gas release of a certain size at a particular location and at a particular time of year could have 

greater economic or environmental effects than a release of considerably more barrels under different 

circumstances of location and season (BOEM 2014a). For more information on the possible impacts of 

catastrophic spills in each OCS planning area see the supporting Economic Inventory Report 

(BOEM 2014a). For an analysis of impacts specific to the GOM see the GOM Catastrophic Spill Event 

Analysis (BOEM 2017). 

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USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Although there is always the potential for accidents resulting in an oil spill and/or gas release, industry, 

USCG, BSEE, and BOEM require numerous safeguards for OCS drilling, development, and production 

operations, which have increased in the post-Deepwater Horizon era. These industry practices and 

government rules, resulting from several recommendations from multiple investigations, have improved 

protocols to increase safety measures. 

Furthermore, requirements place a greater emphasis on operational training and preparation. The Safety 

and Environmental Management System is a performance-based program designed to help drive the 

safety and environmental performance of OCS oil and gas operators and contractors beyond attaining full 

compliance with BSEE regulations. Risk management is the foundation upon which BOEM and BSEE 

regulate and enforce standards. The risk management strategies employed by BOEM, BSEE, USCG, 

USDOT Pipeline and Hazardous Materials Safety Administration, and industry serve as an integral 

component of a safety culture designed to integrate technological and human elements. This integration 

is necessary to ensure safe and environmentally sound OCS operations. Both risk management and 

BOEM and BSEE regulatory oversight greatly reduce the potential for accidental spills. 

7.3 RELATIVE ENVIRONMENTAL SENSITIVITY AND MARINE PRODUCTIVITY 

7.3.1 Summary of Methodology 

BOEM is required, per Section 18(a)(2)(G) of the OCS Lands Act, to consider the relative environmental 

sensitivity and marine productivity of the OCS when making decisions regarding the schedule of lease 

sales for the National OCS Program. For the 2017–2022 Program, BOEM built upon previous 

assessments of these two environmental considerations using an improved model to analyze relative 

environmental sensitivity and taking advantage of technological advancements to estimate marine 

primary productivity. The environmental sensitivity and marine productivity analyses are intended to be 

used by the Secretary as one of many considerations when developing the National OCS Program. The 

current approach to determining relative environmental sensitivity takes into account both the 

vulnerability and resilience of an OCS region’s ecological components to the potential impacts of OCS oil 

and gas activities within the context of existing conditions (e.g., ecosystem change). 

For this DPP analysis, all 26 OCS planning areas are included in the sensitivity analysis. However, for 

the purposes of this analysis, planning areas could be grouped together within a BOEM ecoregion. The 

methodology applied to analyze the relative environmental sensitivity for the 2019–2024 Program is 

identical to that used in the 2017–2022 Program. Some updates and improvements have been made based 

on input from public comments, updated scientific information, and changes in regulations. For example, 

the de-listing of the Eastern DPS of Steller sea lion and changes in commercial fishery landings caused 

some adjustments to the species selections in some of the BOEM ecoregions. Details can be found later 

in this chapter. During the development of the 2019–2024 Program, BOEM will continue to adjust and 

refine this sensitivity analysis. 

Primary productivity estimates for the planning areas were generated using satellite-based measurements 

of chlorophyll-a, available light, and photosynthetic efficiency (Balcom et al. 2011). These parameters 

were input into the Vertically Generalized Production Model (VGPM) to provide estimates of net primary 

productivity (NPP). These methods are identical to the methods used in the 2017–2022 Program and 

reflect the updated approach used for the 2012–2017 Program. 

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7.3.2 Relative Environmental Sensitivity 

7.3.2.1 Background 

Relative environmental sensitivity is not a commonly applied concept in ecology. BOEM previously 

examined environmental sensitivity using two different approaches in the development of the 

2007–2012 Program. The first analysis employed the NOAA environmental sensitivity index (ESI) 

(CSA 1991a, CSA 1991b, NOAA 2002), which quantifies the sensitivity of shorelines based on geology, 

biological resources, and human use resources. This original approach only considered shoreline impacts 

from oil spills and did not consider impacts on other ecological features, such as benthic and pelagic 

fauna and habitats. BOEM presented an expanded relative environmental sensitivity analysis in the 

revised 2007–2012 Program and the 2012–2017 Program in an effort to expand three variables: (1) the 

geographical extent; (2) the BOEM-regulated impacts considered; and (3) the ecological components 

considered in the analysis. This methodology combined the potential impacts on vulnerable organisms 

into an index of sensitivity. This index incorporated four model components, including coastal habitats, 

marine habitats, marine fauna, and marine primary productivity. 

Building upon this expanded analysis, the approach for the 2017–2022 Program incorporated not only the 

sensitivity of the OCS, but also accounted for its “resilience,” which is the ability of the OCS ecosystem 

to resist fundamental change and to recover from impacts. Relative environmental sensitivity thus 

incorporates both the vulnerability and resilience of a region’s ecological components to the potential 

impacts of OCS oil and gas activities in the context of existing environmental conditions. This new 

method was first applied in the 2017–2022 DPP. 

7.3.2.2 Methods 

BOEM’s current approach to relative environmental sensitivity builds upon earlier methods. This method 

was developed through a BOEM-funded contract with the objectives of repeatability and scientific rigor. 

Several alternative methods were evaluated and considered; however, none of these alternative methods 

met BOEM’s mission needs. The chosen approach treats all regions of analysis equally without bias to 

area, presence of existing BOEM activities, or differences in species composition. This current method is 

not biased by spatial inequalities of data availability and weighs all species and habitats equally. It also 

allows unbiased comparison of geographic areas of differing size. Figure 7-18 outlines the complete 

process for determining the sensitivity scores. The following sections provide some details of the 

environmental sensitivity method and a full description is available in BOEM (2014). Since its 

development, this method has been adopted in a simplified form for use by NOAA for oil spill planning 

and response in Alaska (NOAA 2015). 

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Figure 7-18: Environmental Sensitivity Score Methodology 

7.3.2.3 Geographic Scope 

For the analysis of environmental sensitivity, an ecosystem-based approach was used. BOEM’s planning 

areas are administratively constructed designations that do not necessarily correspond to ecosystem 

boundaries. For this DPP analysis of the planning areas, the OCS was divided into nine regions, referred 

to here as BOEM ecoregions (see Figures 7-19 and 7-20). 

The boundary designations for these BOEM ecoregions were informed by the original ecoregion concept 

(Spalding et al. 2007), and were based primarily on LME boundaries (Sherman and Duda 1999). Marine 

ecoregions are areas that are differentiated by species composition and oceanographic features 

(Spalding et al. 2007, Wilkinson et al. 2009). LME boundaries are based on bathymetry, hydrography, 

productivity, species composition, and trophic relationships. BOEM ecoregions account for the distinct 

physical and ecological characteristics of the various OCS regions, while simultaneously meeting 

BOEM’s mission needs. 

In addition to the numerical scores provided for the planning areas in Figures 7-19 and 7-20, the intensity 

of the shading corresponds to the magnitude of these scores. The outlines of the BOEM ecoregions, 

which are the geographic units of analysis, are also shown. 

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Figure 7-19: Relative Environmental Sensitivity for the Alaska Region Planning Areas 

Figure 7-20: Relative Environmental Sensitivity of Lower 48 States Planning Areas 

Note: The Mid-Atlantic Planning Area is split between two BOEM ecoregions: the Southeast and 

Northeast U.S. Continental Shelf ecoregions. 

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The seaward extent of the BOEM ecoregions used in this analysis is largely governed by the U.S. EEZ 

and BOEM planning areas’ seaward boundaries (see Figure 1-1). The use of BOEM ecoregions allowed 

for the analysis of geographic regions that are ecologically similar and contain similar habitat types and 

faunal assemblages. The initial method description (BOEM 2014b) used the terms “broad OCS region” 

and “ecoregion” somewhat interchangeably. However, the boundaries of the broad OCS regions used in 

this analysis do not fully align with North America’s ecoregions, as traditionally defined 

(Wilkinson et al. 2009). Thus, to avoid confusion or inaccuracies, the spatial unit of analysis for 

environmental sensitivity will only be referred to as a “BOEM ecoregion” in this document. 

The bulk of the scientific information available for this analysis was ecosystem-based or focused on 

individual faunal groups and their ecologies. In an effort to treat all regions of the OCS equally and not 

bias the analysis through data patchiness, the BOEM ecoregions were created with boundaries that were 

ecologically meaningful and for which sufficient data were available for model input. The majority of the 

BOEM ecoregions encompass more than one planning area (see Figures 7-19 and 7-20). It is assumed 

that planning areas within the same BOEM ecoregion share the same environmental vulnerability and 

resilience to potential impacts from oil and gas exploration and development. Thus, the same sensitivity 

score was assigned to all planning areas within each BOEM ecoregion. The one exception was the MidAtlantic Planning Area, which was divided across two BOEM ecoregions (the Southeast U.S. Continental 

Shelf and Northeast U.S. Continental Shelf). The Mid-Atlantic Planning Area score was calculated as the 

area-weighted average of these two BOEM ecoregions (see below for details). Table 7-5 provides a 

crosswalk of the 26 planning areas and the nine corresponding BOEM ecoregions in which they are 

located. 

The sensitivity scores from this DPP analysis are based on the vulnerability and sensitivity of the species 

and habitats within each unit of analysis—the BOEM ecoregions. Thus, areas with the same ecological 

characteristics will have the same sensitivity score. An analysis using planning areas as geographic units 

would use the same data and support multiple planning areas with similar ecologies. Therefore, such an 

analysis would be redundant, and the result would be identical to an analysis conducted by BOEM 

ecoregion. Section 7.1 provides additional information about each BOEM ecoregion, including 

geographical area, physical oceanography, ecological features, and human use. Some additional 

distinguishing characteristics and explanations for the creation of these BOEM ecoregions are outlined in 

the following paragraphs. 

The Alaska Region contains three BOEM ecoregions: the Chukchi and Beaufort Seas, the East Bering 

Sea, and the Gulf of Alaska. 

The Chukchi and Beaufort Seas BOEM ecoregion is characterized by an arctic climate and considerable 

ice cover throughout most of the year. This BOEM ecoregion spans two LMEs: the Chukchi Sea and the 

Beaufort Sea. The Chukchi Sea covers a broad shelf and water depths are primarily less than 165 feet. 

In contrast, the Beaufort Sea is much deeper (3,300 feet). Although these two LMEs have different 

oceanographic characteristics, they share similar habitat and species assemblages (Wilkinson et al. 2009). 

Due to these shared similarities in ecosystem function, the two LMEs are roughly equivalent for the 

model’s purposes and were therefore analyzed together as the Chukchi and Beaufort Seas BOEM 

ecoregion. Thus, the Chukchi Sea and Beaufort Sea planning areas have identical scores. 

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Table 7-5: Crosswalk of BOEM Ecoregions and Planning Areas 

BOEM Ecoregion Planning Area 

Beaufort and Chukchi Seas Beaufort Sea 

Chukchi Sea 

Eastern Bering Sea Norton Basin 

St. Matthew-Hall 

Navarin Basin 

Bowers Basin 

St. George Basin 

Aleutian Basin 

Bowers Basin 

North Aleutian Arc 

Gulf of Alaska Aleutian Arc 

Shumagin 

Cook Inlet 

Kodiak 

Gulf of Alaska 

Washington and Oregon Washington/Oregon 

California Current Northern California 

Central California 

Southern California 

Western and Central Western Gulf of Mexico 

Gulf of Mexico Central Gulf of Mexico 

Eastern Gulf of Mexico Eastern Gulf of Mexico 

Northeast U.S. North Atlantic 

Continental Shelf Mid-Atlantic* 

Southeast U.S. Mid-Atlantic* 

Continental Shelf South Atlantic 

* The Mid-Atlantic Planning Area is split between two BOEM 

ecoregions: the Southeast and Northeast U.S. Continental Shelf 

BOEM ecoregions. 

The East Bering Sea BOEM ecoregion comprises the portion of the East Bering Sea LME that lies within 

the United States. This BOEM ecoregion has a broad shelf and seasonal ice cover. This region is 

nourished by nutrient-rich deep bottom water that originates in the Antarctic Ocean and flows along the 

seafloor the length of the Pacific Ocean to the continental shelf seaward of the Aleutian Island chain. 

From there, it flows up onto the Bering Sea continental shelf via a series of submarine canyons, making it 

a very productive benthic marine ecosystem. 

The Gulf of Alaska BOEM ecoregion lies entirely within the U.S. waters of the Gulf of Alaska LME. 

The Alaska Peninsula bisects the East Bering Sea LME and the Gulf of Alaska BOEM ecoregion. The 

Alaska Current flows from east to west along this portion of the OCS. This subarctic LME typically has 

little to no ice cover because the Alaskan Peninsula separates the Gulf of Alaska from the influence of the 

cold Arctic currents. 

The U.S. west coast is divided into two BOEM ecoregions: the California Current and the 

Washington/Oregon. These two BOEM ecoregions constitute the California Current LME, a temperate 

LME characterized by coastal upwelling. This LME is named after the current of the same name that 

moves southward along the western coast of North America from British Columbia, Canada, to 

Baja, California. 

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The Washington/Oregon BOEM ecoregion was considered separately from the rest of the California 

Current BOEM ecoregion due to biological and physical differences. The Washington/Oregon BOEM 

ecoregion lies on the Juan de Fuca tectonic plate. This area north of the Mendocino Escarpment is 

shallower than the seafloor of the Pacific plate to the south. The seafloor has multiple seamounts that 

support a large number of unique species and habitats, such as hydrothermal vents. Submarine canyons in 

this ecoregion establish upwelling conditions that drive high levels of biologic productivity. The 

Washington/Oregon BOEM ecoregion is part of the Columbian Pacific ecoregion, which houses the 

greatest oyster and clam production in North America, as well as resident populations of the endangered 

killer whale (Wilkinson et al. 2009). 

The GOM comprises a single LME, encompassing more than 1.5 million km2 (NOAA 2017a). However, 

for this DPP analysis, the GOM was divided into two BOEM ecoregions—the Eastern GOM and the 

Western and Central GOM—along the Eastern/Central GOM Planning Area boundary. This boundary is 

not only administrative; there are several physical and biological justifications for this division. The line 

between these two ecoregions follows the De Soto Canyon off the coast of Alabama and traces the eastern 

edge of the Loop Current, which effectively divides the GOM. The northern edge of the boundary marks 

the westward edge of the West Florida Escarpment (part of the wide continental shelf along the eastern 

boundary of the GOM). Although both GOM ecoregions share similar habitat and species assemblages, 

there are some key differences, which are discussed in Section 7.1.3. 

The Atlantic planning areas are divided into two BOEM ecoregions, the Northeast U.S. Continental Shelf 

and the Southeast U.S. Continental Shelf. These two BOEM ecoregions are based primarily on the two 

LMEs of the same name. The location of this division is based on the physical oceanographic 

distinctions, with the primary feature being the two major surface currents of the western Atlantic Ocean: 

the Gulf Stream and the Labrador Current. The warm Gulf Stream flows along the east coast of the 

United States from Florida to North Carolina, where it bends northeastward toward deeper water until 

Newfoundland, Canada. The colder Labrador Current flows southward from the Labrador Sea along the 

Canadian coast and terminates off the coast of North Carolina (Wilkinson et al. 2009). Both LMEs are 

productive and support multiple commercial fisheries. The Mid-Atlantic Planning Area straddles the two 

BOEM ecoregions; the sensitivity score for this area was calculated by averaging the scores of the 

Northeast and Southeast U.S. Continental Shelf BOEM ecoregions, and weighted by the percentage of the 

Mid-Atlantic Planning Area in each BOEM ecoregion. Using geographic information system (GIS) 

software, this percentage was calculated as 68.7 percent within the Southeast U.S. Continental Shelf 

BOEM ecoregion and 31.3 percent within the Northeast U.S. Continental Shelf BOEM ecoregion. 

7.3.2.4 Selection of Impacts, Species, and Habitats 

The vulnerability and resilience of selected species and habitats to IPFs were determined for each BOEM 

ecoregion. A comprehensive list of impacts and IPFs from BOEM-regulated activities was generated 

from recent EISs, notices to lessees and operators, and regulatory documents. Each specific IPF was 

assessed for its comparative relevancy and overall potential impact on species and habitats on the OCS. 

Only IPFs considered to have the greatest potential impacts were included in the analysis (see 

BOEM 2014b). These potential impacts were then grouped into the following categories of IPFs: oil 

spills, artificial light, collisions with above-surface structures, habitat disturbance, sound/noise, accidental 

spills, and vessel strikes. In the original method, a temporal overlap of these activities with the presence 

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USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

of the species was incorporated into the model. However, this led to an inadvertent bias in lower 

sensitivity scores for those species that were not present year round in their BOEM ecoregions. For the 

analysis in this DPP, it was therefore assumed that all impacts and all species could occur year round. 

BOEM is considering options on how to best include this temporal variability in future versions of this 

model. 

The environmental resources that could be vulnerable to impacts from BOEM-regulated activities include 

not only individual fauna, but also their habitats. Thus, both habitats and species were chosen as 

parameters in the environmental sensitivity analysis. The species component was organized into four 

groups: (1) mammals and sea turtles; (2) birds; (3) fish; and (4) invertebrates. These groups were selected 

to ensure broad representation across the diversity of organisms that inhabit marine and coastal waters. 

Species were chosen using the criteria of conservation importance, ecological role, and fisheries 

importance (for fish and invertebrates only). The primary measure to determine conservation importance 

is Federal listing status under the ESA (NMFS 2017c). The ecological role for fish and invertebrates was 

based on abundance and importance as a prey or keystone species.38 Fisheries importance was prioritized 

based on commercial landings weight data reported by NMFS. Species could be scored only once for 

each BOEM ecoregion. Four species each for the fish, birds, and invertebrate categories and five species 

for the marine mammal and turtle category were selected for each BOEM ecoregion. The number of 

species in each of the categories was determined to achieve a balance between providing adequate 

representation while maintaining a practical level of effort in sensitivity assessments and impact scoring. 

For details on the selection process for species and the data supporting these selections, see 

BOEM (2014). 

The habitat parameters are comprised of the physical or biological features that support organisms or 

communities and have ecologically distinct properties. Habitat parameters were selected to ensure broad 

and diverse representation in coastal and marine areas within the BOEM ecoregion. The habitat 

categories were shoreline, estuarine, and marine. The determination of shoreline parameters, using 

NOAA’s ESI shoreline classification scheme (NOAA 1995, NOAA 2002), was based on all digital ESI 

shoreline data available as of 2017 (NOAA 2017d). Only oil spills were assumed to potentially impact 

coastal habitats. Although the bulk of BOEM-regulated activities occur in Federal waters miles from 

shore, shoreline habitats are at risk during spills due to the likelihood of being directly oiled when floating 

slicks impact the shoreline. Shoreline habitat scores were derived with methods set forth in 

BOEM (2014) using current NOAA ESI data (NOAA 2017e). The estuarine and marine habitats were 

selected based on their ecological role or importance in terms of their contribution to regional biodiversity 

and overall productivity. For a full description of the habitat selection process, see BOEM (2014). 

BOEM has reevaluated the initial species and habitat selection in the original model since its adoption and 

application in the development of the 2017–2022 Program. All species and habitats were examined for 

this DPP to ensure that their selections were still valid based on the criteria prescribed in the 

methodology. BOEM relied upon public comments, updates to Federal regulations (such as ESA 

listings), and best available science to inform this review, and determined that some changes in selected 

species were warranted. Some of these “new” species were included in the 2017–2022 Proposed 

Program, but some are included in this DPP for the first time. A list of all changes in species and their 

38 Keystone species are defined as a species on which other species in an ecosystem largely depend, such that if it 

were removed, the ecosystem would change drastically. 

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selection rationale is shown in Table 7-6. All other species and all habitat selections remain the same as 

provided in BOEM (2014). 

The environmental sensitivity of the selected species and habitats was assessed with respect to potential 

impacts of oil and gas activities occurring on the OCS. This assessment was based on the quantification 

of the species’ and habitats’ vulnerability and resilience to potential oil and gas impacts. Vulnerability 

was evaluated as the probability that a species/habitat would be exposed to an impact, and it was based on 

the spatial overlap between a given species/habitat and an impact. The resilience was based on the 

intolerance of a habitat or species to a given impact and that species’ or habitat’s recovery potential. 

Resilience was not predicated on previous exposure of a species or habitat to oil and gas impacts, but 

rather on best available data relating to ecological characteristics, tendencies, and trends, such as species’ 

reproductive rates and habitat recovery potential. Likewise, sensitivity was not based on the probability 

of an impact occurring, because all impacts were assumed to occur everywhere on the OCS. 

7.3.2.5 Impact-independent Modifiers 

The model was designed to accommodate the consideration of impact-independent modifiers 

(e.g., climate change, productivity, and unregulated impacts). An ecosystem change vulnerability score 

was included as a scaling factor, which was added to the base sensitivity scores for each BOEM 

ecoregion. Using the same approach as used in the 2017‒2022 Program analysis, the anticipated effects 

of climate change, including changes in temperature, sea ice melt and freshwater influx, permafrost thaw, 

ocean acidification and upwelling effects, sea level rise and saltwater intrusion, increased storm activity, 

and changes in species composition, were assessed for each BOEM ecoregion. A magnitude for each 

expected impact due to climate change was assigned to each BOEM ecoregion using a relative scale 

(0 to 2, depending on intensity of effects; see Table 7-7). These sub-scores were summed for a total 

ecosystem change score. This score was then converted to an ecosystem change index with a scale of 

0 to 4. This scale was chosen to allow an appropriate weight for impact-independent factors in the final 

environmental sensitivity score. 

Relative environmental sensitivity scores were calculated for each habitat and species selected for each of 

the nine BOEM ecoregions (see Table 7-8). These scores (which also include the shoreline ESI) form the 

foundation of the total environmental sensitivity score. The species and habitat scores were normalized 

before combining them. The ecosystem change index was then added to this base score for a final 

sensitivity score. No theoretical maximum sensitivity score is possible for a BOEM ecoregion. Such a 

maximum is dependent upon the number of parameters included in the model (such as the number of 

species and habitats) and would therefore be mathematically impossible to achieve given the mechanics 

of the model. For the purposes of the OCS Lands Act, however, such a maximum is not necessary, 

because that Act requires an analysis to determine “relative” environmental sensitivity (i.e., a comparison 

of all the regions). BOEM’s methodology achieves that comparison. 

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Table 7-6: Species Selected that Differ from the Original Environmental Sensitivity Analysis (BOEM 2014) 

Species 

Selected Replaces Selection 

Criteria Selection Rationale Reference 

Chukchi/Beaufort Sea BOEM Ecoregion 

chum salmon dolly varden fisheries 

importance 

The annual (weight) catch of chum salmon is 

higher than dolly varden. Dolly varden is not an 

important commercial fishery in the Arctic. 

Menard et al. 

2017 

red king crab blue king 

crab 

fisheries 

importance 

No commercial fishing occurs in the Arctic 

except for several small state-managed fish 

species. King crabs (Paralithodes spp.) are 

fished for subsistence purposes in the 

southeastern Chukchi Sea, but the species is not 

identified. The red king crab was chosen to 

replace the blue king crab as a representative 

species because red king crabs are becoming 

increasingly common in Arctic waters, including 

the Beaufort Sea, and is a more important fishery 

in Alaskan waters than blue king crab. 

ADF&G 

2017c; 

NMFS 2017b, 

NMFS 2017d 

Eastern Bering Sea BOEM Ecoregion 

black-legged 

kittiwake 

pigeon 

guillemot 

ecological 

role 

The black-legged kittiwake is more abundant 

than the pigeon guillemot in the Eastern Bering 

Sea. 

Denlinger 

2006, 

eBird 2017 

Gulf of Alaska BOEM Ecoregion 

beluga whale sperm whale conservation 

importance 

The Cook Inlet beluga whale stock is endangered 

and has designated critical habitat in the BOEM 

ecoregion. Additionally, public input on the 

previous National OCS Program suggested 

including the beluga whale. The sperm whale is 

endangered but does not have critical habitat 

designated. 

Muto 

et al. 2017 

harbor seal northern fur 

seal 

ecological 

role 

The harbor seal is highly abundant, and its range 

is more focused within the Gulf of Alaska than 

the northern fur seal. The harbor seal is an 

important predator species in the planning area. 

Northern fur seals are rarely found within the 

Cook Inlet, the part of the ecoregion where 

BOEM-regulated activities are most likely to 

occur. 

ADF&G 

2017d, 

ADF&G 

2017e, 

Muto 

et al. 2017 

hooligan/ 

eulachon 

Pacific 

herring 

conservation 

importance 

The Pacific herring is no longer under 

consideration for ESA listing. Although only the 

southern DPS of eulachon is listed, the Alaskan 

population is also in steady decline. 

ADF&G 

2017f, 

ADF&G 

2017g, 

MMS 2003, 

NMFS 2017e 

Pacific cod pink salmon fisheries 

importance 

The Pacific cod is a more appropriate choice for 

fisheries importance than the pink salmon due to 

its higher landings by weight. 

NMFS 2017b 

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Species 

Selected Replaces Selection 

Criteria Selection Rationale Reference 

black-legged 

kittiwake 

glaucouswinged gull ecological 

role 

The black-legged kittiwake is more abundant 

than the glaucous-winged gull in the Gulf of 

Alaska BOEM ecoregion. 

Denlinger 

2006, eBird 

2017 

Washington/Oregon BOEM Ecoregion 

harbor 

porpoise 

Dall’s 

porpoise 

ecological 

role 

The harbor porpoise is the most abundant marine 

mammal in the BOEM ecoregion (minimum 

population estimate of about 48,000 animals). 

The Dall’s porpoise’s current minimum 

population estimate is just under 18,000 animals. 

Carretta 

et al. 2017 

California Current BOEM Ecoregion 

sperm whale Steller sea 

lion 

conservation 

importance 

The Steller sea lion was de-listed in 2013. The 

sperm whale is federally endangered with a very 

low potential biological removal* (2.7 animals). 

Carretta 

et al. 2017, 

NMFS 2017c 

Western/Central Gulf of Mexico BOEM Ecoregion 

laughing gull doublecrested 

cormorant 

ecological 

role 

The laughing gull is highly abundant along the 

Gulf Coast. The double-crested cormorant is 

very abundant but has a wide inland distribution, 

making it a less appropriate choice for OCS 

sensitivity. 

eBird 2017; 

O’Connell 

et al. 2011 

brown 

pelican 

magnificent 

frigatebird 

ecological 

role 

The brown pelican is highly abundant along the 

Gulf Coast. The magnificent frigatebird is less 

abundant in the BOEM ecoregion. 

eBird 2017 

Eastern Gulf of Mexico BOEM Ecoregion 

laughing gull doublecrested 

cormorant 

ecological 

role 

The laughing gull is highly abundant along the 

Gulf Coast. The double-crested cormorant is 

very abundant but has a wide inland distribution, 

making it a less appropriate choice for OCS 

sensitivity. 

eBird 2017 

brown 

pelican 

magnificent 

frigatebird 

ecological 

role 

The brown pelican is highly abundant along the 

Gulf Coast; the magnificent frigatebird is less 

abundant. 

eBird 2017 

Southeast U.S. Continental Shelf BOEM Ecoregion 

striped 

mullet 

vermilion 

Snapper 

fisheries 

importance 

The striped mullet is the second highest landed 

fishery by weight in the BOEM ecoregion. 

NMFS 2017b 

sanderling Wilson’s 

storm-petrel 

ecological 

role 

The sanderling is abundant in the BOEM 

ecoregion, migrates along the coast, and is a 

species of concern. The Wilson’s storm-petrel is 

less abundant in the BOEM ecoregion. 

eBird 2017; 

O’Connell 

et al. 2011 

laughing gull doublecrested 

cormorant 

ecological 

role 

The laughing gull is highly abundant along the 

southeastern Atlantic coast. The double-crested 

cormorant is very abundant but has a wide inland 

distribution, making it a less appropriate choice 

for OCS sensitivity. 

eBird 2017; 

O’Connell 

et al. 2011 

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Species 

Selected Replaces Selection 

Criteria Selection Rationale Reference 

Northeast U.S. Continental Shelf BOEM Ecoregion 

northern 

gannet 

doublecrested 

cormorant 

ecological 

role 

The northern gannet has a very high density in 

the BOEM ecoregion. The double-crested 

cormorant is very abundant but has a wide inland 

distribution, making it a less appropriate choice 

for OCS sensitivity. 

eBird 2017 

* = Potential biological removal is the maximum number of animals, not including in natural mortalities that could be removed 

annually from a marine mammal stock while allowing that stock to reach or maintain its optimal sustainable population level. 

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Table 7-7: Scoring of Anticipated Ecosystem Change Impacts for BOEM Ecoregions 

BOEM Ecoregion 

Anticipated Ecosystem Change Impacts 

Temperature 

Change 

Sea Ice Melt 

& Freshwater 

Influx 

Permafrost 

Thaw 

Ocean 

Acidification/ 

Upwelling 

Effects 

Sea Level 

Rise & 

Saltwater 

Intrusion 

Increased 

Storm 

Activity 

Changes in 

Species 

Composition 

Total 

Ecosystem 

Change 

Index 

Chukchi/Beaufort Sea 2 2 2 2 0.5 1 1 8.5 2.4 

East Bering Sea 2 2 1.5 2 0.5 1 1 8 2.3 

Gulf of Alaska 2 1 1 1 0 1 1 5 1.4 

Washington-Oregon 1 0 0 1.5 1 0 1 3.5 1.0 

California Current 1 0 0 0.5 0 0 1 1.5 0.4 

Western Gulf of Mexico 0.5 0 0 0.5 2 1 1 4.5 1.3 

Eastern Gulf of Mexico 0.5 0 0 0.5 1 1 1 3.5 1.0 

Southeast U.S. 

Continental Shelf 1 0 0 0.5 1.5 1 1 4 1.1 

Northeast U.S. 

Continental Shelf 1.5 0 0 1.5 2 1 1 5.5 1.6 

Notes: Total score reflects the climate change score prior to the conversion to an ecosystem change index with a maximum score of four. Scores were assigned based on a scale of 0–2 and then 

summed for all anticipated effects. A score of 0 was given to BOEM ecoregions in which little to no effect was expected; a score of 1 assigned to BOEM ecoregions in which a low to intermediate 

effect was expected; and a score of 2 assigned for intermediate to high anticipated effects. Before summing the climate change index with the habitat and species sensitivity scores, the total ecosystem 

change scores in the table were converted to a scale of 0–4. 

Sources: Fabry et al. 2009, Jones et al. 2009, Haufler et al. 2010, Smith et al. 2010, Doney et al. 2012, USEPA 2013, IPCC 2014, Melillo et al. 2014, Ekstrom et al. 2015, NOAA 2017f, USGCRP 2017, 

USDA 2017. 

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Table 7-8: Environmental Sensitivity Score by BOEM Ecoregion 

BOEM Ecoregion Environmental 

Sensitivity Score 

Western and Central GOM 19.6 

Chukchi and Beaufort Sea 19.2 

Southeast U.S. Continental Shelf 19.2 

Eastern GOM 19.1 

East Bering Sea 17.9 

Washington/Oregon 17.9 

Northeast U.S. Continental Shelf 17.8 

Gulf of Alaska 17.3 

California Current 15.7 

7.3.2.6 Results and Discussion 

The environmental sensitivity scores for the planning areas range from 15.7 to 19.6 with an average score 

of 18.2 ± 1.2 (see Table 7-8 and Figure 7-21). These scores are unitless and serve as an index of 

environmental sensitivity. The small range in sensitivity scoring demonstrates that all planning areas are 

sensitive to oil and gas activities—some more so than others. Further, what drives this sensitivity differs 

from BOEM ecoregion to BOEM ecoregion based on varying species and habitat sensitivities, as well as 

anticipated impacts of ecosystem change to these ecoregions. 

The BOEM ecoregion with the highest sensitivity score was the Western GOM (19.6). This high score 

results from the ecoregion having the highest species and habitat component scores. Interestingly, the 

high total species score is not due to any single species with a high sensitivity score but rather a collection 

of species with relatively high scores, especially for some of the birds (laughing gull and brown pelican), 

fish (red snapper and endangered Gulf sturgeon), and invertebrates (American oyster). The high habitat 

score for the Western GOM is primarily driven by the ESI and benthic marine habitat scores. The 

Southeast U.S. Continental Shelf and Eastern GOM had the highest ESI scores, and the Western GOM 

had a fairly high shoreline index. These high ESI scores are due a predominance of saltwater marshes, 

swamps, and other vegetated wetlands along the shores of those ecoregions (NOAA 2017g). The 

Western GOM also had the highest marine benthic habitat score, which is comprised of fine, 

unconsolidated substrate, seeps, and deepwater coral. 

The Chukchi/Beaufort Sea and the Southeast U.S. Continental Shelf BOEM ecoregions had the second 

highest sensitivity score (19.2). For the Arctic region, this higher score is largely due to the ecoregion 

receiving the highest ecosystem change index (3 out of 4) and a relatively high species score. The high 

species score was driven by the high bird sensitivity scores, especially for the endangered spectacled 

eider. 

In the Southeast U.S. Continental Shelf BOEM ecoregion, the score was driven by a moderately high 

species score, which included the highest marine mammals and sea turtles sub-score of all BOEM 

ecoregions. This high species score is a result of some high-scoring species with low reproductive 

potential and high ages of maturity, such as the Florida manatee and Atlantic sturgeon. 

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Figure 7-21: Aggregated Sensitivity Scores for Habitats, Species, and Ecosystem Change by Planning Area 

0 

5 

10 

15 

20 

Sensitivity Score 

Species Habitat Ecosytem Change Index 

For similar reasons, the beluga whale and Atlantic sturgeon led to relatively high species scores for the 

Gulf of Alaska, and Northeast U.S. Continental Shelf BOEM ecoregions, respectively. 

Prior to the addition of the impact-independent modifier of ecosystem change, the California Current and 

East Bering Sea were tied for the lowest sensitivity score (15.0). The relatively higher ecosystem change 

score in the East Bering Sea (2.9 out of 4) resulted in the California Current being the lowest scoring 

BOEM ecoregion. The low scores for these two ecoregions are the result of low habitat and species 

scores. Both BOEM ecoregions had relatively low ESI scores and no high-scoring species. 

The relatively small differences among the environmental sensitivity scores suggest that differentiation 

among the BOEM ecoregions based on the total score alone would be difficult. Rather, the environmental 

sensitivity is one tool of many that BOEM uses to make decisions regarding the development and 

exploration of oil and gas resources on the OCS. This model is driven by the best available scientific 

information at the geographic scale of analysis, and BOEM strives to incorporate empirical data, where 

available. Similar approaches can be taken to evaluate proposed activities on particular areas of the OCS 

on a case-by-case basis. OCS regions should be individually considered with a full understanding of the 

species present, their distributions, and habitat needs, and therefore, the individual sensitivity to potential 

oil and gas activities. 

7.3.3 Marine Productivity 

7.3.3.1 Background 

Productivity is a term used to indicate the amount of biomass produced over a period of time. Primary 

productivity is the production of biomass using carbon dioxide and water through photosynthesis. The 

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primary productivity of the marine community is its capacity to produce energy for its component species, 

which sets limits on the overall biological production in marine ecosystems. Primary production in the 

marine environment is conducted primarily by phytoplankton; macroalgae, such as Sargassum or kelp; 

and submerged aquatic vegetation like seagrasses. The rate at which this occurs is based largely on the 

organisms’ ability to photosynthesize. The methods of measuring phytoplankton productivity are 

relatively standard and results normally are expressed in terms of chlorophyll-a, or the amount of carbon 

fixed during photosynthesis per square meter of ocean surface per unit of time. 

Phytoplankton can occupy all surface waters of an OCS planning area and fix carbon, as long as sufficient 

light and nutrients are available. Farther from shore, nutrient availability could limit productivity. 

Additionally, surface mixing due to wave action, down-welling, fronts, and convergence carry 

phytoplankton to depths in the water column where light is insufficient for photosynthesis to occur. 

The difference between the energy produced during photosynthesis and the amount of energy expended 

during this process is known as NPP. The rate of NPP determines the amount of energy that is available 

for transfer to higher trophic levels (i.e., position in the food chain) (Ware and Thompson 2005, 

Chassot et al. 2010). Thus, the most critical aspect of marine productivity is NPP, which is the focus of 

this analysis. 

The productivity of higher trophic levels (e.g., secondary and tertiary production) is more difficult to 

constrain than primary productivity. Although some models of secondary and tertiary productivity exist 

for OCS regions, estimates are not available for all planning areas (Balcom et al. 2011). Unlike primary 

production, secondary production is difficult to validate with empirical measures. Due to the limitations 

of existing data and inequalities in data availability among all planning areas and habitat types 

(Balcom et al. 2011), secondary and tertiary production estimates are not robust and will not be presented 

for decision support. 

7.3.3.2 Methods 

In 1991, BOEM (then MMS) completed a primary productivity review (CSA 1991a, CSA 1991b). The 

1991 study produced estimates by tabulating the results of individual studies conducted in each planning 

area. These estimates relied on studies that used different methodologies, spatial scales, and/or sampling 

frequencies. The approach used in this DPP analysis is identical to the methods and results presented in 

the 2017–2022 Program. This current method greatly improves on these previous productivity estimates 

using new tools and technology that have become available since the 1991 report. 

The current primary productivity study uses satellite-based observations to provide input parameters for 

the VGPM to estimate NPP in each planning area as a function of chlorophyll-a, available light, and 

photosynthetic efficiency. The satellite-based measurements, which feed the VGPM, are available at a 

resolution of 1 km, allowing BOEM to analyze the primary productivity of the OCS at the planning area 

spatial scale. The years of analysis, 1998–2009, were constrained by the earliest availability of the 

satellite data and the conclusion of the BOEM-funded study (Balcome et al. 2011). Productivity 

determinations were depth-integrated, extending from the ocean surface to the euphotic depth (i.e., the 

depth where 1 percent of the surface light, or photosynthetically available radiation, is available). This 

depth ranged from a maximum of 100 meters (i.e., within ocean gyres) to a minimum of several meters 

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(e.g., within eutrophic coastal waters). For a more detailed discussion of methods, see 

Balcom et al. (2011). 

7.3.3.3 Results and Discussion 

In this DPP analysis, each of the 26 planning areas is characterized in terms of areal coverage, mean 

annual NPP, annual and monthly variance, and trend (i.e., increasing or decreasing productivity) over a 

12-year period (1998–2009). Productivity ranged from 30.5 (Beaufort Sea) to 413.5 metric tons of carbon 

per square kilometer per year (t C km-2 yr-1) (Cook Inlet) (see Figure 7-22 and Table 7-9). Regional 

trends are detailed as follows: 

• Alaska Region: High NPP variability existed in the Alaska Region, which housed both the 

highest and the lowest rates of NPP on the OCS. It should be noted that the accuracy of primary 

productivity estimates for the Alaska Region could be substantially lower than other regions for 

several reasons. For example, the presence of turbid coastal waters could adversely affect remote 

sensing measurements (i.e., chlorophyll-a concentrations can be significantly overestimated 

[> 100 percent] from satellite measurements due to algorithm artifacts in the atmospheric 

correction and bio-optical inversion). Variations in seasonal solar insolation effects also could 

result in reduced primary productivity (e.g., most of the areas in the Alaska Region have limited 

sunlight). 

• Pacific Region: In general, the Pacific Region exhibited the highest annual primary productivity 

per square kilometer: > 300 t C km-2 yr-1 for all four planning areas. Within the region, the 

highest annual NPP was evident in the Central California Planning Area; the lowest NPP was 

found in the Southern California Planning Area. 

• GOM Region: The GOM Region exhibited high annual primary productivity per square 

kilometer: 283 t C km-2 yr-1 for all three planning areas. The highest annual NPP was evident in 

the Central GOM; lowest NPP was found in the Eastern GOM Planning Area. 

• Atlantic Region: The NPP within the Atlantic Region was highly variable, with an average NPP 

of 217 t C km-2 yr-1 . The North Atlantic Planning Area housed the highest annual NPP, while the 

Mid-Atlantic, South Atlantic, and Straits of Florida planning areas’ NPPs were much lower. 

Although calculations are based on the VGPM model, and there are various studies showing the validity 

of this model in assessing primary productivity in marginal seas and upwelling systems, some degree of 

uncertainty is expected from the model as applied to all 26 OCS planning areas. 

Substantial interannual variability in primary productivity is found in several of the planning areas, with 

the highest interannual variability evident in the Alaska Region. Ten of the 15 Alaska planning areas 

exhibited interannual variability greater than 10 percent, all of which are located in high latitudes 

(i.e., variability due to light limitation). In contrast, most of the remaining planning areas from the other 

three regions show low interannual variability (< 10 percent). Low-latitude areas are less sensitive to 

cloudiness, provided the cloud cover is not persistent. 

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Figure 7-22: Marine Annual Net Primary Productivity 

0 

100 

200 

300 

400 

Areal NPP (metric tons C km-2 yr -1) 

Note: Values represent the mean and the standard deviation of 12 annual values for the 1998–2009 period, standardized per unit 

area. 

Marine ecosystems can be affected significantly by the rates and magnitude of primary production within 

their boundaries. Alterations in primary production in an ecosystem will have wide-ranging effects on all 

dependent species and chemical processes occurring within the affected system. Having sufficient 

knowledge of the magnitude and rates of primary production within an ecosystem allows for an accurate 

understanding of the overall potential productivity within that system. This knowledge could help 

elucidate the potential effects that altering the base of the food chain could have on dependent species and 

processes. Therefore, it is important to include estimates of primary production in any analysis of 

environmental sensitivity related to OCS oil and natural gas activities. Besides any direct effects of an oil 

spill on higher trophic levels, any anthropogenic alteration of the base of the food chain, such as spilled 

oil on the surface of the ocean resulting in decreased light penetration, and thus decreased rates of 

photosynthesis of a system, would necessarily affect the functioning of the system as a whole. However, 

these effects on primary production most likely would be very short-term and of low magnitude. 

Comparison of 1990 and 2010 primary productivity determinations indicates that the model-derived 

estimates in the present analysis are in good agreement with literature-based determinations; 22 of the 

26 OCS planning areas exhibited similar productivity estimates, based on minimal-maximal ranges. 

Given the completely different assessment and, therefore, independent methods between the two periods, 

this similarity provides strong support for the argument that model results (based on satellite data) provide 

excellent estimates of primary productivity. 

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Table 7-9: Net Primary Productivity Rates 

Planning Area Areal NPP 

(t C km-2 yr-1) 

Cook Inlet 413.5 ± 28.1 

North Atlantic 366.7 ± 22.8 

Norton Basin 347.2 ± 40.8 

Central California 340.7 ± 37.9 

Central GOM 324.2 ± 34.0 

Washington/Oregon 312.8 ± 25.9 

North Aleutian Basin 302.5 ± 52.5 

Western GOM 294.4 ± 27.1 

Northern California 288.3 ± 17.3 

Southern California 279.0 ± 30.4 

Gulf of Alaska 275.5 ± 10.6 

St. George Basin 254.7 ± 36.3 

St. Matthew-Hall 235.9 ± 32.6 

Hope Basin 231.5 ± 51.5 

Eastern GOM 231.3 ± 26.7 

Kodiak 229.7 ± 11.6 

Shumagin 228.2 ± 17.6 

South Atlantic 225.5 ± 20.2 

Navarin Basin 194.3 ± 45.5 

Aleutian Basin 186.1 ± 14.3 

Aleutian Arc 185.1 ± 24.9 

Bowers Basin 169.5 ± 17.5 

Straits of Florida 153.5 ± 13.1 

Mid-Atlantic 122.2 ± 5.7 

Chukchi Sea 42.0 ± 21.4 

Beaufort Sea 30.5 ± 24.1 

Key: t C km-2 yr-1 =metric tons of carbon per 

square kilometer per year, NPP=net primary 

productivity. 

Within the 1998–2009 primary productivity dataset, significant variability in primary productivity 

determinations was evident, particularly in the Alaska Region. Although some of this variability could be 

attributed to planning area-specific oceanographic features and/or local processes, some variability could 

be reflective of the data acquisition method. The accuracy of satellite-derived productivity estimates 

could be affected by one or more factors, including the overestimation of chlorophyll-a concentration 

from satellite measurements (particularly in the Alaska Region) due to algorithm artifacts in the 

atmospheric correction and bio-optical inversion; seasonal solar insolation effects are evident 

(i.e., predominantly in the Alaska Region where sunlight is limited during the winter months), and 

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uniform application of the NPP model could be slightly problematic for marginal seas and areas of 

upwelling. 

Productivity ranged from 30.5 (Beaufort Sea) to 413.5 (Cook Inlet) t C km-2yr-1 (see Figure 7-22 and 

Table 7-9). The Alaska Region exhibited high NPP variability. It should be noted that the accuracy of 

primary productivity estimates for the Alaska Region could be substantially lower than in other regions 

for several reasons, as mentioned above. 

Despite these challenges, BOEM required an approach that could be consistently applied and compared 

across broad areas. Field-based methods suffer from variations in analysis, geographic coverage, 

temporal coverage, and other standardization issues. BOEM maintains that the current methodology 

(i.e., satellite-based measurements) is the best method available to measure NPP for the purposes of 

BOEM decisionmaking. Additionally, it should be highlighted that these are annual averages taken over 

a 12-year period. The Arctic is known to house high rates of NPP (Shakhaug 2004); however, these rates 

are measured during seasonal blooms (Springer and McRoy 1993, Hill and Cota 2005). The low light 

availability in the Arctic contributes to low annual averages of NPP. 

The GOM Region exhibited high annual primary productivity: 314.4 t C km-2yr-1 for the entire basin. On 

a regional basis, the Central and Eastern GOM Region had a higher rate of NPP than the Western GOM. 

In conclusion, NPP is highly variable on the OCS, with a nearly 14-fold difference between the lowest 

rates (found in the Beaufort Sea and Chukchi Sea planning areas) and the highest rates (found in the Cook 

Inlet Planning Area). These rates of NPP allow a ranking of the planning areas; areas with high rates of 

primary production would have the greatest amount of energy available to higher trophic levels in that 

area (i.e., the amount of biomass that area could potentially support). The low productivity in the 

Beaufort Sea and Chukchi Sea planning areas is largely due to the long periods of low light availability in 

the region. 

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Chapter 8 Equitable Sharing Considerations 

8.1 DEFINITION AND INTRODUCTION 

Section 18(a)(2)(B) of the OCS Lands Act requires that the Secretary base the size, timing, and location 

of the OCS exploration, development, and production on a consideration of “an equitable sharing of 

developmental benefits and environmental risks among the various regions.” 

To assist the Secretary in making decisions, this analysis considers the sharing of benefits and risks to the 

U.S. population, particularly in the coastal areas that produce, or could potentially produce, oil and gas. 

As recognized by the court in California II, the OCS regions are submerged lands off the U.S. coast. 

Because most developmental benefits and environmental risks to society occur onshore or along the coast, 

BOEM uses PADDs (see Section 6.2) to help assess the sharing of benefits and risks among onshore 

“regions” (see Section 8.3). 

In the past, the regions possessing substantial oil and gas resources (and the adjacent areas) included in 

previous National OCS Programs received most of the benefits from developing OCS resources. These 

regions have also been subject to the associated environmental risks of developing those resources. While 

developing the 2019–2024 Program, BOEM considers how this relationship will evolve in the 

consideration of areas for future oil and gas development. At the DPP stage, this analysis is driven by 

general considerations that provide a simple basis for judging the implications of programmatic decisions 

on equitable sharing of developmental benefits and environmental risks. This analysis discusses the 

potential developmental benefits and environmental risks that could accrue to areas proximate to an OCS 

producing region, as well as those widely distributed benefits and risks that could accrue to the entire 

United States. The Secretary is required to consider equitable sharing, but neither Section 18 of the OCS 

Lands Act nor the courts have indicated a specific distribution of sharing that a new National OCS 

Program should achieve. 

Regional sharing of benefits and risks is heavily influenced by the distribution of oil and gas and 

environmental resources. A key consideration is whether areas are given an equitable opportunity to 

develop and benefit from nearby resource endowments. That does not mean that every region must be 

included in lease sales under the National OCS Program; to the contrary, it must be considered that some 

regions possessing substantial oil and gas resources might also be prone to serious environmental risks, 

and the law gives the Secretary wide latitude to assess the relative importance of a variety of factors in 

deciding the size, timing, and location of sales that best meet the energy needs of the United States (see 

Section 1.2 for a description on energy needs). 

As noted in Chapter 5, in the absence of leasing under a new National OCS Program, energy substitutes 

would be required to replace the forgone OCS oil and gas. Energy market substitutes change the relative 

developmental benefits and environmental risks experienced by the U.S. These impacts from no leasing 

under a new National OCS Program are discussed briefly in Section 8.4. 

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The developmental benefits in the equitable sharing analysis at all three stages of National OCS Program 

development are calculated using an economic impact approach. This differs from the benefit-cost 

approach used to estimate the NSV in Chapter 5. Economic impact analysis and benefit-cost analysis 

offer two means of estimating certain measures of benefits and costs, and both approaches provide 

valuable information for the National OCS Program decision analyses. Each approach reflects different 

aspects of economic activity. 

The effects measured in a benefit-cost analysis represent direct first-order real resource market outcomes, 

such as increased production and the accompanying increase in economic surplus, as well as the costs 

imposed by the proposed National OCS Program lease sale schedule. Some factors, such as employment, 

often thought of as a benefit to society, are treated in a benefit-cost analysis as costs paid by society to 

conduct the activities that result in economic value. For example, the NSV analysis in Section 5.3 starts 

with the calculation of NEV of OCS leasing. In this calculation, costs of exploration, development, and 

transportation are netted from the gross value of the resources in each planning area to estimate the value 

of the extracted resources in each planning area. Alternatively, in an economic impact analysis these 

same costs generate income, employment, and revenues that state and local governments and residents 

generally consider to be benefits. Thus, the economic impact analysis focuses on these broad 

macroeconomic measures, such as income, employment, wages, and revenue transfers, as they could 

relate to specific industries and geographic locations. 

An additional distinction between the benefit-cost analysis and the economic impact analysis is the 

geographic scope of analysis. Because the Secretary must make programmatic decisions for the benefit of 

the United States as a whole, the benefit-cost approach presents relative benefits and costs from a national 

perspective (described in Section 5.3). The NSV analysis does not outline costs and benefits specific to a 

particular area, but instead focuses on costs and benefits that accrue to the United States as a whole. 

However, for the equitable sharing analysis, it is the benefits enjoyed and distributed risks borne among 

the specific geographic regions that are most important. Therefore, the economic impact analysis 

evaluates developmental benefits and risks at a regional level. 

In the Proposed Program and PFP, the equitable sharing analysis will focus specifically on the program 

areas under consideration for future oil and gas activity and the Program Options presented. The 

discussion at that stage will outline the developmental benefits and environmental risks that could be 

directly felt nearby, as well as those benefits and risks that could occur in other regions. The Proposed 

Program and PFP equitable sharing analysis will also describe in more detail the widely distributed 

benefits and risks that could occur as a result of OCS oil and gas activities. 

8.1.1 Consideration of Elements Beyond the Secretary’s Control 

The OCS Lands Act gives the Secretary wide latitude to assess the importance of a variety of factors in 

deciding the size, timing, and location of lease sales that best meet the energy needs of the United States. 

In addition to the elements listed above, there are dynamics that can greatly affect the equitable sharing 

implications of the National OCS Program, but which are not under the direct control of the Secretary. 

For example, regardless of any Secretarial decision, the geographic distribution of oil and gas resources 

can limit the developmental benefits an area could receive. Environmental factors, such as weather or ice 

cover, could also affect the actual incidence of environmental risk in an area. 

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Other factors beyond the Secretary’s control include laws that can prohibit oil and gas exploration in 

certain areas or that can discourage companies from timely operation on the OCS. Employment, income, 

and tax benefits in each region can change if localities change their relevant policies and laws. While 

sharing of oil and gas revenues as well as impact assistance, can be important in determining the 

distribution of benefits to regions, these policies are generally resolved through legislation and are 

therefore often outside the scope of the Secretary’s ability to affect by his decisions. These types of 

factors could ultimately change the actual developmental benefits and environmental risks experienced as 

a result of OCS oil and gas activity. 

8.2 REGIONAL BENEFITS AND RISKS 

8.2.1 Regional Benefits 

There are benefits from the development and production of oil and gas resources that accrue primarily to 

producing regions and nearby onshore populations. These benefits include the impact on local economies 

from expenditures associated with production (i.e., labor, land, materials, and equipment). Exploration, 

development, and production—and many of the industries that support such activities—generally result in 

additional jobs and employment at higher-than-average pay and spending on these activities reverberates 

throughout the economy. Although some groups might not welcome these development impacts, most 

communities consider them a benefit. Additional benefits to communities proximate to OCS oil and gas 

activities come from revenue sharing programs, increased tax collections, and benefits from producing 

energy near where it is consumed. 

8.2.1.1 Additional Jobs and Increased Wages 

Jobs and their associated labor income are among the most important benefits to many local communities. 

Employees are needed by industry to conduct oil and gas operations and in many other industries that 

support oil and gas exploration, development, production, and transportation. Through the creation of 

additional income and employment, the spending of these employees generates multiplier effects 

throughout the local economy. These indirect and inducted effects generate spending in local economies 

much greater than those of the initial industry expenditure. 

The employment impact generated from OCS leasing during the 2019–2024 Program will differ 

depending on the planning areas included in the National OCS Program and whether or not current 

activity exists in the area. For example, in the GOM where OCS oil and gas activities have been 

occurring for decades, most of the employment benefits of the new National OCS Program are the 

continuation of current jobs. Maintenance of, and perhaps an increase in, benefits for states adjacent to 

the region would occur through the continuation of GOM areawide sales, and/or in the event that more of 

the Eastern GOM Planning Area is made available for leasing with the expiration of the Congressional 

moratorium in this area occurring on June 30, 2022. 

Alternatively, in areas without a developed oil and gas industry, an emerging oil and gas industry could 

result in low, immediate local economic effects for nearby communities that might be perceived as 

beneficial. A large proportion of workers during the exploration and development phases are likely to be 

sourced from other places, and early benefits could be greatly affected by the availability of existing 

infrastructure that can support the industry. A unique characteristic of offshore oil and gas development 

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is extended work schedules (e.g., one week on, followed by one week off duty). These types of schedules 

allow workers to commute long distances. For example, in the Alaskan Arctic, employees would likely 

live in southern Alaska, other communities within the United States, or other countries, and would 

commute to work where they would be housed in separate worker enclaves while on duty. In new areas 

of OCS development (e.g., the Atlantic), the long schedules would likely result in many of the skilled 

workers commuting from the GOM area initially, with local workers gradually increasing in proportion if 

exploration and development activities increase and continue. Actual economic effects would vary 

depending on the maturity and composition of the OCS region. 

For the USDOI Economic Contribution Report, BOEM calculates an annual estimate of the jobs 

supported by OCS oil and gas development (USDOI 2017). In the report, BOEM considers the 

employment generated from industry spending, industry profits, and government revenue. For FY 2016, 

BOEM estimates that approximately 315,000 jobs were sustained from OCS oil and gas activities. Of the 

aggregate employment, BOEM estimates that approximately 70 percent of jobs remain in the states 

adjacent to the GOM (i.e., Texas, Louisiana, Alabama, Mississippi, and Florida) (see Table 8-1). 

BOEM’s economic impact calculations use regional economic impact models, collectively called 

MAGPlan,39 to estimate the economic effects of OCS oil and gas activities. A more detailed analysis of 

effects anticipated from each decision option will be conducted for the areas included in the Proposed 

Program and PFP analyses. The states experiencing significant employment will very likely expand if 

new areas are available for leasing and exploration and development occurs. 

Table 8-1: FY 2016 Employment Associated with OCS Oil and Gas Development 

State Estimated 

Jobs 

Alabama 20,000 

Florida 8,000 

Louisiana 52,000 

Mississippi 15,000 

Texas 124,000 

Rest of U.S. 95,000 

Total 315,000 

Note: Totals may not sum due to rounding. 

Source: USDOI 2017 

Although it is impossible to precisely locate all jobs in an industry with work patterns like those of the 

OCS oil and gas industry, OCS leasing and subsequent activities would particularly contribute to local 

economies near the planning areas selected. In addition, many of the jobs in the oil and gas industry earn 

a significant wage premium. Figure 8-1 shows the average hourly earnings of employees in the oil and 

gas extraction industry as compared to the average hourly earnings of employees in all private industries. 

Oil and gas extraction jobs earn more than 150 percent of the average hourly wage of other employees. In 

turn, these employees have more purchasing power and can consume more goods and services, 

benefitting them by increasing their standard of living and contributing relatively more to the economy. 

39 BOEM has three separate MAG-Plan models to calculate economic impacts, one model each for Alaska (Northern Economics, 

Inc. et al. 2011), the GOM (Kaplan et al. 2016), and the Atlantic (Kaplan et al. 2017). 

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Figure 8-1: Nominal Average Hourly Earnings of U.S. Workers 

$0 

$5 

$10 

$15 

$20 

$25 

$30 

$35 

$40 

$45 

$50 

2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 

Oil and Gas Extraction Total Private 

Source: BLS 2017a and BLS 2017b 

In addition to OCS development, onshore infrastructure is needed to support oil and gas development. 

Significant existing infrastructure for oil and gas development exists near the GOM. In the Beaufort Sea, 

Cook Inlet, and Southern California planning areas, the existing infrastructure network is smaller and 

more focused around state-level projects. For the other planning areas, new infrastructure construction is 

likely to be associated with successful exploration. Construction and development of onshore support 

infrastructure would likely generate additional regional economic effects as measured by employment, 

labor income, and government revenues. Employment and income would be generated during the 

exploration, development, and production phases from the construction of any necessary onshore support 

infrastructure (e.g., service base, air support base, pipelines, roads, onshore processing facilities, oil spill 

response base). However, in some areas such as the less-developed, less-populated areas of the Alaska 

North Slope and Bering Sea coasts, it is likely that some construction work would be performed with 

nonlocal labor. Onshore infrastructure also brings environmental risks, which are discussed in general in 

Section 8.3.2. 

8.2.1.2 Increased Tax Collection 

OCS oil and gas production increases the economic contribution to local economies through spending and 

investment, and provides a meaningful contribution to state and local tax revenues. In addition to 

employment and labor income, development of high-value onshore infrastructure to support OCS oil and 

gas activities would generate property tax revenues that accrue to the jurisdiction in which the 

infrastructure is located. 

The importance of tax revenue varies by region. Tax revenues, especially from property taxes generated 

by facilities serving onshore and offshore state oil and gas activities, are very important to Alaska and 

many of its boroughs and local communities. The GOM has extensive onshore infrastructure that 

contributes to local and state economies and funds government services. Should frontier areas become 

areas of similar long-term development and production, this tax revenue would contribute to state and 

local economies in these areas, as well. 

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The extent to which communities near oil and gas activities would benefit from infrastructure 

development would depend on a number of factors, including the current capacity of infrastructure to 

support oil and gas activities. For example, the GOM already has a well-developed web of infrastructure 

and would not require extensive development of new facilities to serve new activity (e.g., from expanded 

Eastern GOM leasing). The Atlantic coast has areas with significant general infrastructure (e.g., roads, 

housing, medical facilities) to meet some of the needs required for potential new exploration and 

development, but new infrastructure will be needed to support production activities. There are numerous 

construction companies and labor sources in both the Atlantic and Pacific, and these regions could benefit 

from local infrastructure construction associated with new leasing opportunities in these areas. However, 

in the less-developed, less-populated areas of the Alaska North Slope and Bering Sea coasts, it is likely 

that some construction work would be performed with non-local labor. 

In addition to construction of new infrastructure, production from this National OCS Program would 

extend the economic life of regional onshore infrastructure that depends on oil and gas. This is especially 

true for the GOM and Alaska, where local economies—and even state and local treasuries—depend on 

revenues from continued use of existing infrastructure. An important example is the TAPS, which 

transports oil from the Prudhoe Bay area of the Alaskan Arctic and depends on future development of 

OCS or additional onshore oil to remain active. Communities along the GOM and in southern California 

similarly benefit from continued operation of facilities constructed to service OCS operations, although 

these areas are not as singularly dependent on the industry as is the Alaskan Arctic. 

8.2.1.3 Revenue Sharing 

Revenue sharing, a method of providing economic benefit to those regions that bear the environmental 

risks of proximate OCS oil and gas activities, affects equitable sharing among regions. Only Congress 

has the authority to expand, extend, or otherwise revise revenue sharing provisions during the period 

covering future National OCS Programs. Currently, two statutes have created programs that provide OCS 

oil and gas revenues to the coastal producing states and political subdivisions: Section 8(g) of the OCS 

Lands Act and GOMESA. 

Section 8(g) applies to all coastal states adjacent to current or potential areas of OCS development, and 

provides for coastal states and the Federal Government to share revenues earned from OCS leases in 

Federal waters between the state’s submerged lands boundary and 3 nautical miles seaward. This 

3-mile-wide area adjacent to the state’s submerged lands boundary is known as the “8(g) zone.” BOEM 

shares 27 percent of these bonus, rent, and royalty revenues with the adjacent states. The 8(g) revenues 

are intended to compensate the states for any drainage of resources in state waters by Federal lessees. 

Table 8-2 shows the 8(g) revenue dispersed to the six states sharing 8(g) leasing revenues from OCS 

production. 

In addition to the Section 8(g) revenue sharing, GOMESA also provides substantial revenue sharing. 

GOMESA became law in 2006 and provides revenue sharing for Alabama, Louisiana, Mississippi, Texas, 

and their coastal political subdivisions (i.e., counties or parishes), and provides revenue to the LWCF, 

which distributes revenue more widely for approved projects. The GOMESA revenue sharing program 

was designed to compensate for potential negative impacts of, and the additional demand for services and 

infrastructure due to, OCS activities. GOMESA funds are reserved for uses specified in the Act, 

including coastal restoration and protection. 

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Phase 1 of GOMESA provided for the uncapped sharing of a 37.5 percent share of OCS revenues from 

selected areas stipulated in the law, which are included in the Central and Eastern GOM planning areas.40 

The second phase of GOMESA began in FY 2017 and includes the sharing of additional GOM oil and 

gas lease revenues (limited to $500 million annually). All revenues from applicable GOM leases issued 

during the 2019–2024 Program will be subject to these GOMESA revenue sharing provisions. 

Table 8-

2 shows the 8(g) and GOMESA revenue distributions for FY 2016. 

Table 8-2: FY 2016 8(g) and GOMESA State Disbursement Summary 

State 8(g) GOMESA 

Alabama $1,537,555 $90,774 

Alaska $1,064,323 N/A 

California $1,648,042 N/A 

Louisiana $6,313,683 $102,714 

Mississippi $51,779 $83,987 

Texas $134,617 $36,731 

Total $10,750,000 $314,205 

Key: N/A=Not Applicable. Alaska and California do not receive 

GOMESA revenues. 

Source: ONRR 2017a 

While the Secretary cannot expand, extend, or otherwise revise revenue sharing provisions to further the 

equitable sharing of the developmental benefits and environmental risks during the period covering the 

next National OCS Program, Congress has the authority to do so. If Congress decides that the current 

distribution of benefits and costs is inequitable, it can modify the existing arrangement or extend similar 

revenue sharing agreements to additional states if oil and gas exploration and development expands to 

new areas of the OCS. 

8.2.1.4 Proximity of Energy 

Another developmental benefit of OCS production is the production of oil and natural gas near oil and gas 

consumers. The transportation of energy products such as oil and gas is expensive, especially if new 

transportation infrastructure is needed due to major shifts in production location, and it introduces risks 

along the routes. Producing energy close to where it is refined or processed and consumed reduces costs 

incurred by energy suppliers and can improve economic efficiency, reduce environmental impacts from 

transportation, and decrease potential impacts on fuel distribution due to disruptions from events such as 

natural disasters. 

The GOM planning areas are near ample refinery capacity whereas the Pacific and Atlantic planning 

areas are near major consumption points. However, for OCS production to be able to support nearby 

communities, refineries would have to have enough excess capacity to refine or process the resources. 

Although the Alaskan Arctic planning areas are not in close proximity to most consumers, production of 

OCS oil would increase throughput of the TAPS, potentially helping to extend the life of the pipeline and 

providing Alaska with valuable revenue. Other areas of Alaska do have a local market for the resources, 

40 More information on GOMESA revenue sharing is available on BOEM’s website at http://www.boem.gov/Revenue-Sharing/. 

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such as the Cook Inlet which provides natural gas to Anchorage. More discussion of the national and 

regional energy markets is included in Chapter 6. 

8.2.2 Regional Risks 

Chapter 7 discusses some of the potential impacts associated with oil and gas development on the OCS. 

Further information on the environmental risks (potential impacts) will be addressed in the Draft and 

Final Programmatic EISs to be published concurrently with the Proposed Program and PFP decision 

documents, respectively. The Programmatic EIS describes the biological, physical and sociocultural 

resources that could be impacted by oil and gas leasing activities. The burden of environmental risk is 

borne primarily by the marine and coastal areas adjacent to and within which oil and gas activities occur. 

This is due to the fact that potential environmental impacts from oil and gas activities (and associated 

ramifications to the human population) are often linked to the proximity of the actions that could cause an 

impact. The risks associated with non-routine or accidental events such as oil spills could be higher in 

areas with the greatest activity or in areas where the oceanography or characteristics of the environment 

could lead to more oil reaching the shoreline. 

The discussion of risk associated with oil and gas activities on the OCS varies slightly in scale from the 

discussion of benefits. Benefits that could accrue to the regions proximate to ongoing oil and gas 

activities include an increase in jobs and wages and the subsequent multiplier effects that could be felt 

more widely. This benefit could be smaller at the outset (i.e., in frontier areas where exploration is the 

primary activity) and grow as development and production allow the industry to become established. In 

the case of environmental risk, the impacts are often within the waters of the OCS and in the immediate 

coastal zone. These impacts, particularly ones that have economic consequences, could be apparent 

throughout the local and state economies. However, the burden of environmental risk is borne primarily 

by the marine and coastal areas adjacent to and within which oil and gas activities occur. 

Risks to marine and coastal resources generally are characterized as the chance that the human, coastal, or 

marine environment could be harmed as a result of oil and gas leasing activities associated with the 

2019–2024 Program. A decision not to lease could carry risks from activities required to obtain and 

transport energy substitutes. Generally speaking, with leasing, environmental risk is greater in areas 

where there is more oil and gas activity. 

In areas with new oil and gas development, it is often necessary to construct or modify supporting 

onshore infrastructure. While construction of onshore infrastructure can bring employment, more and/or 

better roads, and other benefits, it also poses environmental, socioeconomic or sociocultural, and/or fiscal 

risks, especially if the oil and gas activity is short-lived and does not provide local communities with the 

revenues to compensate for upfront expenditures or under-used facilities. 

In addition, especially in non-industrialized areas, there could be the need for additional development of 

general infrastructure, such as higher-capacity roads and more housing, which can impose costs to both 

the natural and human environments, along with the benefits that could result. 

Onshore construction could result in a variety of adverse impacts including the destruction or alteration of 

existing habitat such as wetlands or nesting areas for turtles and birds, permanent or temporary 

displacement of species that rely on those habitats, and behavioral disruption that could have acute or 

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long-term impacts on individuals and populations. In the GOM, an extensive onshore infrastructure 

support network is already in place and will not require significant new development or modification, 

potentially lowering the environmental risks associated with coastal development. In the Atlantic and 

Pacific, there are areas of important sea turtle and bird habitat. However, the level of human use and 

infrastructure development in these regions are high, and those ecological issues are already a part of the 

local and regional planning process. Even though some onshore infrastructure systems needed to support 

new offshore OCS development would be novel to these areas, balancing important environmental issues 

with human use is not. In Alaska, the area around the Cook Inlet Planning Area and certain parts of the 

coast adjacent to the Beaufort Sea Planning Area have existing infrastructure in place (including those 

supporting state oil and gas production). Other areas, such as the majority of the Arctic coast, have very 

little and would require significant development of onshore facilities. Additional risks from onshore 

construction in Alaska are associated with the potential disruption of subsistence resources, such as access 

to hunting areas or disturbance of animals such as caribou. 

Oil spills are another possible risk borne by OCS regions and the coastal areas adjacent to OCS activities. 

Different OCS regions have different risk factors that affect the probability of oil spills. For example, the 

principal risk that applies to deep water drilling in the GOM occurs as a result of drilling and 

containment/response risks associated with the use of drilling technologies at these depths. In the Arctic, 

the primary risks stem from ice and the ability to drill relief wells. Similarly, different regions would be 

impacted differently by oil spills. In the GOM, a deep water, large-volume spill could have more 

environmental consequences than a smaller spill occurring in shallow water. However, depending on the 

site conditions and location, deep water spills could impose less risk on highly valued coastal areas due to 

their distance offshore, which allows for more natural weathering and dispersion. In the Arctic, an 

ongoing concern is the environmental effects from a large oil spill on sensitive marine and coastal habitats 

within the land-sea-ice biome that supports a traditional subsistence lifestyle for Alaska Native peoples 

and provides important habitats for migratory and local animal populations. The ability to respond to and 

contain a very large discharge event under the extreme climatic conditions and seasonal presence of ice 

could present an especially great risk. 

8.3 WIDELY DISTRIBUTED BENEFITS AND RISKS 

8.3.1 Widely Distributed Benefits 

As discussed, many of the developmental benefits of the National OCS Program occur in onshore areas 

adjacent to the planning areas included in the lease sale schedule. In addition to these benefits, substantial 

benefits also accrue to the United States as a whole, as widely distributed benefits. The oil and gas 

industry is integrated with the rest of the U.S. economy; therefore, growth and profitability in the oil and 

gas sector have positive and far-reaching economic impacts. Current employment benefits from OCS 

leasing are largest in states with the most oil and gas activity happening off their coasts, namely Texas 

and Louisiana. However, OCS leasing supports thousands of jobs and millions of dollars in GDP (value 

added) in coastal and inland states alike throughout the United States. Benefits flowing from Federal 

leasing revenues (bonuses, rents, and royalties) tend to be widely distributed among the geographic 

regions of the United States. Although portions of certain revenues are distributed regionally to states 

through 8(g) and GOMESA revenue sharing programs, the vast majority of leasing revenues are 

disbursed into the U.S. Treasury General Fund and then appropriated by Congress for various Federal 

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functions. In FY 2016, OCS oil and gas leasing provided approximately $2.8 billion in leasing revenues, 

which accrue to the general treasury (ONRR 2017b). In addition to the leasing revenues collected from 

OCS activity, oil and gas activities on the OCS generate a significant amount of tax revenue to the 

U.S. Treasury. As general treasury revenues, the money is spent throughout the country for programs 

such as national defense or benefits programs. Future OCS leasing and development will also contribute 

to the national benefits received from additional oil and natural gas production. 

A small percentage of OCS funds is appropriated to the Historic Preservation Fund and the LWCF. The 

Historic Preservation Fund was created to provide grants to states, Tribes, local governments, and 

nonprofit organizations to preserve historic places. The LWCF provides assistance to states and local 

efforts to acquire land for parks and recreation facilities. Because states and organizations around the 

country can apply for grants and assistance, these funds provide national benefits from OCS development 

as well as help to offset or mitigate environmental risk for communities near oil and gas activities. The 

Trust for Public Land conducted a study on the return on LWCF investment and found that every 

$1 invested returned $4 in economic value from natural resource goods and services (The Trust for Public 

Land 2010). 

As described in Section 8.3.1.1, the various equipment and supplies required for an OCS oil and gas 

project, as well as the industry’s work schedules, allow for vendors, suppliers, and employees to be 

located throughout the United States. Vendors can be located and employees can live and spend their 

wages far from the areas adjacent to the OCS, thereby contributing money from OCS jobs to local 

economies perhaps hundreds of miles from the OCS. Whereas approximately 70 percent of the total 

employment and GDP contribution of GOM OCS activities are concentrated in the GOM states, the 

remainder is shared throughout the United States (as shown in Table 8-1). 

Along with leasing and tax revenues and employment benefits, OCS oil and gas activities generate 

substantial industry profits that provide dividends to shareholders, and serve as a source of investment 

capital to ensure future growth and innovation. These outcomes positively impact the entire economy to a 

significant degree. 

Development of the OCS provides other national benefits that are less easily quantified. One of these 

benefits is a reduction in the U.S. trade deficit, with reduced dependence on imported oil. Domestic 

energy production also reduces risks to national security and adds to supply that can fulfill U.S. energy 

needs. These national benefits from OCS production are discussed in more detail in Chapter 1. 

In addition to receiving the financial and national security benefits that result from OCS oil and gas 

development, the United States also receives benefits from the reduced need to rely on substitute sources 

of energy. As will be discussed in more detail in the Proposed Program and PFP decision documents, the 

production of OCS resources reduces the U.S. need for additional onshore oil and natural gas production, 

increased oil imports, and fuel switching to coal or other sources of electricity. In some cases, the areas 

that have OCS production will also be the same areas where reduced substitutes are needed (e.g., OCS 

production from the GOM reduces the need for imports, resulting in lower risks of spills from tankers 

traveling through the GOM). However, in other instances, the social and environmental costs of OCS 

production are not necessarily realized in the same region as the benefits of not relying on the energy 

substitutes (e.g., Alaska OCS production could result in costs in Alaska, but could also reduce the need 

for additional foreign imports, resulting in a reduced need for, for example, tankers traveling to the 

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Pacific coast). This analysis of the impacts in the absence of leasing under a National OCS Program will 

be expanded for the Proposed Program and PFP analyses, which will consider specific Program Options. 

8.3.2 Widely Distributed Risks 

Environmental risks that could accrue on a national level from oil and gas leasing activities could result in 

a direct impact on human health or economic stability. However, there are many risks that are not easily 

quantified and that could present short- or long-term implications on a national scale. 

Human health and well-being are affected by numerous, interrelated and unrelated activities, including 

the exploration, development, production, and use of oil and gas resources on the OCS. The primary 

direct impact pathway from oil and gas exploration, development, production, and use activities to human 

health is degradation of air quality through emissions. Air pollutant emissions directly impact the health 

and quality of life of humans (e.g., increased prevalence of asthma or other respiratory illnesses) and 

GHG emissions contribute broadly to the effects of global climate change. BOEM also recognizes that 

the marine and coastal ecosystems that could be impacted by oil and gas activities provide a variety of 

other ecosystem services including food, carbon sequestration, recreation, protection from natural 

disaster, and aesthetics. 

While the risks associated with air quality are largely regional, the risks from GHG emissions are national 

and international in scale. Climate change is a global phenomenon, and climate change impacts are a 

function of worldwide GHG emissions, including the contribution of emissions from the National OCS 

Program. In addition, because GHGs, like carbon dioxide, could influence climate over decades to 

millennia, the potential impacts of any source could extend well beyond the active lifetime of the source 

or production associated with the National OCS Program. Refer to the report, OCS Oil and Natural Gas: 

Potential Lifecycle Greenhouse Gas Emissions and Social Cost of Carbon (Wolvovsky and 

Anderson 2016), for estimates of GHGs that could be emitted as a result of the activities associated with 

the 2017–2022 Program and the estimated energy substitutes if no new leasing occurs under an approved 

National OCS Program. 

The environmental risk of a low-probability CDE, such as the Deepwater Horizon accident, is primarily 

regional. However, the compensation costs for such events and for other losses not attributable to specific 

parties are shared by companies and individuals throughout the country. For example, after the 

Deepwater Horizon oil spill, all BP shareholders were affected by compensation liabilities associated 

with the spill. In that case, there was a massive transfer of funds to the GOM coast for cleanup and 

compensation from an international company with widely dispersed operations and stockholders. A less 

dramatic example is the industry payments into the Fishermen’s Contingency Fund, which compensates 

U.S. commercial fishermen and other eligible citizens and entities for property and economic loss caused 

by obstructions related to oil and gas development activities on the OCS, representing individually small, 

widespread costs to provide more concentrated compensation to a few local, negatively affected entities. 

The risks of environmental impacts from the National OCS Program are not limited to the United States. 

The contiguous United States is bounded by Canada on the north and Mexico on the south, and the 

Commonwealth of the Bahamas and Cuba are 50 miles and 110 miles, respectively, from the coast of 

Florida. In the Arctic, the Alaska OCS is bounded by Canada to the east and Russia to the west. These 

countries could experience environmental impacts from oil and gas leasing activities, especially if a CDE 

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occurs in the vicinity and the physical and environmental conditions (e.g., wind direction, current flow) 

are conducive to the spread of oil outside U.S. waters. However, just as activities from the OCS could 

affect these countries, these countries also conduct their own oil and gas activities that, regardless of any 

decision by the United States, would increase the risk to U.S. waters and coasts. Many long-lived marine 

species such as whales, dolphins, sharks, and tuna have distributions or ranges that cross international 

boundaries, as well. Impacts on these species or populations originating within U.S. waters could be 

detectable within the waters of other countries and vice versa. 

8.4 IMPACTS ON BENEFITS AND RISKS IN THE ABSENCE OF LEASES IN A 

NATIONAL OCS PROGRAM 

In the absence of new OCS lease sales, energy substitutes would be required to replace OCS oil and gas to 

fulfill U.S. demand for energy. In development of the National OCS Program, BOEM considers the 

energy market substitutes that would replace OCS oil and gas in the event that no lease sales were 

scheduled in a National OCS Program. Choosing not to develop OCS resources eliminates many of the 

developmental benefits and environmental risks from OCS production from accruing. 

Selecting not to have OCS oil and gas leasing in a particular planning area has different impacts 

depending on the current level of oil and gas activity. In the GOM, where production has occurred for 

several decades, the decision not to have further leasing would result in a decline in U.S. production, 

which in the near term would have to be replaced by other, substitute, sources of energy, most likely 

leading to negative impacts on communities that provide goods, services, and labor to support 

OCSrelated activities or rely on associated revenue for public finance. In other planning areas that have 

little or no current OCS production, the decision to continue to not hold lease sales means substitute 

energy sources are and will continue to be used to fulfill domestic demand. In either case, the substitute 

energy sources have their own developmental benefits and environmental risks. In instances where 

imported oil would replace OCS production, many of the developmental benefits will accrue outside the 

United States, but many of the environmental risks remain because products are still shipped to the U.S. 

BOEM’s OECM uses EIA transportation data to estimate where substitute energy sources would be 

produced if OCS leasing were forgone in a particular area. In addition, the OECM also estimates which 

substitute energy sources would replace the forgone OCS production in a particular planning area 

(Industrial Economics, Inc. and SC&A, Inc. 2015). This analysis will be conducted for the Proposed 

Program and PFP analyses to provide information on the specific trade-offs of the Secretary’s decision to 

hold or not hold a sale. 

8.5 SUMMARY 

The National OCS Program has a certain innate equity in that the geographic areas bearing the greatest 

risks also receive a higher share of the benefits, while certain financial aspects of both benefits and risks 

are shared somewhat widely. In making a DPP decision, the Secretary uses the equitable sharing 

discussion framework to consider whether the accrual of benefits could be worth the environmental risk. 

After the Secretary makes the DPP decision and specifies size, timing, and location of lease sales, a more 

specific equitable sharing analysis will be conducted for later stages of the National OCS Program 

development process. The first specific analysis will be included in the Proposed Program. In addition, 

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the determination of environmental risk will be informed by the development of the impact analysis in the 

associated Programmatic EIS. 

The regional benefits associated with oil and gas activities include increases in employment and wages. 

This could lead to a higher standard of living, increased contribution to local economies through spending 

and investment, and a stable contribution to state and local tax revenues. In frontier areas, these effects 

could be slightly delayed. Construction of onshore infrastructure or use of existing infrastructure could 

increase job creation (such as in Alaska and the Atlantic) or maintain it (as would occur in the GOM). 

Revenue sharing will continue to contribute economic benefits to certain states along the GOM, and with 

Congressional action, could provide similar benefits to other locations near existing or future activity 

(i.e., Alaska, Pacific, and/or Atlantic regions). 

Regional risks include possible environmental impacts that could negatively affect marine and coastal 

resources. These risks include impacts on commercial fishery stocks, other uses of the OCS, or 

availability of subsistence resources. These risks vary greatly depending on the sensitivity of an area to 

perturbation, the types and scale of oil and gas activities, existing OCS activities, and the presence and 

distribution of environmental resources such as fish, birds, or coral reefs. 

Nationally, there are economic benefits associated with oil and gas activities, including employment and 

wage benefits for widely distributed workers and the overall contribution from oil and gas revenues to the 

U.S. economy. National risks include impacts from onshore infrastructure, human health impacts, and 

impacts on coastal and marine ecosystems. However, additional domestic oil and gas production reduces 

the need to obtain oil and gas from other domestic and foreign markets, which could reduce certain 

environmental risks from onshore oil and gas activities, coal and other substitutes, and oil imported by 

tanker, as well as reducing the overall trade deficit and increasing energy security. 

The distribution of benefits associated with factors of production is linked significantly to the location of 

OCS oil and gas support industries, which currently exist primarily along the GOM, Southern California, 

and Alaska coasts. Similarly, the benefits of reducing levels of energy substitutes would depend on 

production locations and transportation patterns. Absent broad restrictions imposed on OCS leasing, the 

Secretary’s decision on an OCS leasing schedule for 2019–2024 could expand areas available for leasing, 

perhaps eventually leading to the development of new OCS-related industries and employment in the 

adjacent communities and possibly creating a more equitable sharing of benefits and risks than achieved 

under previous National OCS Programs. 

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Chapter 9 Industry Interest and Laws, Goals, and Policies of 

Affected States 

9.1 INDUSTRY INTEREST 

OCS Lands Act Section 18(a)(2)(E) (see Section 2.2) requires BOEM to consider the interest of potential 

oil and gas producers. In response to the RFI, BOEM received 10 comment letters from exploration and 

development companies and oil and gas industry associations. Of those responses, most supported 

including all 26 OCS planning areas for further analysis. Table 9-1 summarizes the comments on specific 

planning areas that were received by industry. Summaries of comments from industry are included in 

Appendix A. 

Table 9-1: Summary of Energy Exploration and Production Industry Comments on the RFI 

OCS Planning Area Preference 

Organization Gulf of Mexico Atlantic Pacific Alaska 

Chevron U.S.A., Inc. 1. Central 

2. Western 

3. Eastern 

4. Mid5. North 

6. South 

7. Southern 

California 

OCS Planning Area Mentioned in Comment Letter 

Anadarko Petroleum Corporation X Mid- and South 

API, NOIA, IPAA, USOGA, AEPC, 

IAGC, PESA, AOGA* 

X X X X 

Arctic Slope Regional Corporation 

Exploration, LLC 

Beaufort and 

Chukchi seas 

BP Exploration & Production Inc. X X 

Cobalt International Energy X X X X 

Diamond Offshore X X Beaufort and 

Chukchi seas 

Enven Energy Ventures X 

Shell Oil Company **   **  

Statoil USA E&P, Inc. X X X X 

Notes: 

* = American Petroleum institute, National Ocean Industries Association, Independent Petroleum Association of America, 

U.S. Oil and Gas Association, American Exploration and Production Council, International Association of Drilling 

Contractors, International Association of Geophysical Contractors, Petroleum Equipment Suppliers Association, Alaska Oil 

and Gas Association 

** = Shell recommended access to new OCS areas in its public comment submission without specific reference to planning 

areas or regions. As mentioned in the letter Shell publicly submitted, a second, proprietary letter was submitted that contained 

more specific information.. 

Key: X = a region that was mentioned in the comment letter without specific reference to individual planning areas, or all 

planning areas in the specified region were mentioned. 

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9.2 LAWS, GOALS, AND POLICIES OF AFFECTED STATES 

OCS Lands Act Section 18(a)(2)(F) (see Section 2.2) requires BOEM to consider laws, goals, and polices 

of affected states that are specifically identified by their governors. BOEM received 30 comment letters 

in response to the RFI from governors, or a state agency on behalf of the governor. These letters 

identified laws, goals, and/or policies that the state deemed relevant for the Secretary’s consideration. 

Comments from governors and state agencies are summarized in Table 9-2 and shown in Figure 9-1. 

More detailed comment summaries are presented in Appendix A. Comments are discussed in the 

following sections by OCS region and planning area. The views expressed in these following summaries 

are those of the commenters, not of BOEM. 

Table 9-2: RFI Comment Summaries from Governor and State Agencies 

Commenter(s) Comment Summary 

OCS Governors Coalition (Maine, 

Alabama, Mississippi, Texas, Alaska) 

All planning areas should be included with the understanding that 

circumstances could change during National OCS Program development 

and implementation. 

Alaska Governor Supports leasing and activity in the OCS. Particularly interested in 

Beaufort and Chukchi seas sales in addition to Cook Inlet. 

Alaska Department of Natural 

Resources 

Supports OCS leasing off Alaska. Requests 3 sales in each of 3 areas— 

Beaufort Sea, Chukchi Sea, and Cook Inlet. 

Washington Departments of Ecology, 

Natural Resources, and Fish and 

Wildlife 

Opposes inclusion of areas adjacent Washington. 

Oregon Governor Kate Brown’s 

Office 

Asserts state’s long opposition to oil and gas activity off its coast. 

California Governor Jerry Brown, 

Oregon Governor Kate Brown, 

Washington Governor Jay Inslee 

As part of the West Coast Governors Agreement, the governors strongly 

oppose any new leasing off their coasts. 

California Attorney General Strongly opposes inclusion of any California planning areas. 

California Coastal Commission Opposes new leasing anywhere, but particularly undeveloped areas off 

California. 

California Fish and Game 

Commission 

Passed resolution supporting prohibition of leasing off California. 

California State Lands Commission Opposes new oil and gas leasing in the Pacific OCS. 

Hawaii Governor Opposes leasing off the coast of Hawaii. 

Texas Railroad Commission, Chair Supports inclusion of all 26 planning areas. 

Texas Railroad Commissioners (2) Support inclusion of all 26 planning areas. 

Louisiana Department of Natural 

Resources 

Supports exploration and development throughout the OCS, but the new 

National OCS Program should provide habitat mitigation commensurate 

with the impacts. 

Alabama Governor Kay Ivey Supports balanced and reasonable leasing program in compliance with state 

laws, goals, and policies. Requests no leasing within 15 miles of Baldwin 

County. Did not state position with regard to inclusion of areas offshore 

Alabama in National OCS Program. 

Florida Department of Environmental 

Protection 

Coordinated review by state agencies that stated protection of coastal and 

marine resources should be paramount. 

Florida Department of State Concerned about potential adverse impacts to significant archaeological 

resources. Did not state position with regard to inclusion of areas offshore 

Florida in National OCS Program. 

Florida Fish and Wildlife 

Conservation Commission 

Concerned about environmental sensitivity, marine productivity, and other 

uses of the OCS. Did not state position with regard to inclusion of areas 

offshore Florida in National OCS Program. 

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Commenter(s) Comment Summary 

Georgia Department of Natural 

Resources 

Supports environmentally sound efforts to increase domestic oil and gas 

reserves. Have certain issues that must be considered if Georgia offshore 

waters are included. 

North Carolina Governor Roy 

Cooper 

Requests the current National OCS Program be maintained without leasing 

off the North Carolina coast. 

North Carolina Lt. Governor Supports inclusion of Federal lands off North Carolina. Encourages 

legislative efforts on revenue sharing. 

Virginia Governor Terence 

McAuliffe 

Opposes inclusion of Virginia as revenue sharing is required for support. 

Virginia Lt. Governor Opposes inclusion of Virginia. 

Maryland Department of Natural 

Resources 

Opposes opening up the Mid-Atlantic for oil and gas activities. 

Delaware Governor John Carney Opposed to future leasing, exploration, development, or production of oil 

and gas in the Atlantic. 

Delaware Department of Natural 

Resources and Environmental 

Control 

Has opposed offshore oil and gas exploration in the Mid-Atlantic region for 

more than a decade and sees no economic justification to do so. 

New Jersey Department of 

Environmental Protection 

Strongly opposes consideration of waters off its coast (North and MidAtlantic). 

New York Attorney General, 

Environmental Protection Bureau 

Believes BOEM has a legal obligation to address potential climate change 

implications of a new National OCS Program. 

New York Departments of State and 

Environmental Conservation and 

Energy Research and Development 

Authority 

Believes any renewed consideration of oil and gas development off New 

York would disrupt existing plans for clean offshore wind generation. 

Connecticut Department of Energy 

and Environmental Protection 

Continues to oppose inclusion of the North Atlantic. If either the North or 

Mid-Atlantic is included, certain state laws, goals, and policies must be 

addressed. 

Massachusetts Governor Charles 

Baker 

Does not support inclusion of areas adjacent to Massachusetts. 

Massachusetts Attorney General Strongly opposes opening up any of the Atlantic or any other new areas to 

oil and gas leasing. 

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Figure 9-1: Coastal State Governor or State Agency Responses to Request for Information 

9.2.1 OCS Governors Coalition 

The OCS Governors Coalition was created by governors from coastal states in May 2011 to promote a 

constructive dialogue on OCS energy resource planning and development between coastal state governors 

and Federal policy makers. The bipartisan group of governors supports policies that encourage a safe, 

responsible expansion of offshore oil, natural gas, and renewable energy development for the benefit of 

the Nation, the states, and citizens. The Coalition’s comment letter, signed by Governors Paul LePage 

(Maine), Kay Ivey (Alabama), Phil Bryant (Mississippi), Greg Abbott (Texas), and Bill Walker (Alaska), 

states that they believe it is prudent to include all leasing options in the DPP, understanding that 

circumstances affecting leasing decisions could change during the course of the National OCS Program’s 

development and implementation. They propose that access to offshore energy resources will allow 

coastal states and communities to realize great economic opportunities and that the successful 

development of the GOM and the initial exploration of Alaska’s OCS demonstrate how responsible 

offshore energy development can generate many good paying jobs, spur activity in a host of associated 

industries, and generate billions of dollars in tax revenue. The Coalition also believes that states must 

have an up-to-date assessment of the potential resource base off their coasts to inform decisionmaking 

regarding offshore development and thus welcome the decision to re-evaluate permits to conduct seismic 

surveys in the Mid- and South Atlantic. The Coalition also strongly urges the Administration to support 

existing revenue sharing with states, as well as any legislative efforts to expand revenue sharing to all 

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participating coastal states. Further, they urge that the existing revenue sharing cap for the Gulf states be 

lifted. 

9.2.2 Alaska Region 

The Alaska governor supports responsible leasing and activity in the OCS that is grounded in community 

input and robust environmental protection; this is a state priority and is fundamentally consistent with its 

laws, goals, and policies. The governor attached his letter of October 6, 2016, in which he 

“unambiguously express[ed] the State’s interest in including sales in the Beaufort and Chukchi OCS 

areas” because they were not included in the 2017–2022 Program along with the Cook Inlet lease sale, 

which was the third area that the governor nominated for inclusion in his earlier letter. 

The Alaska Department of Natural Resources believes at least three lease sales should be conducted in 

each of the three primary Alaskan OCS areas—the Chukchi Sea, the Beaufort Sea, and Cook Inlet— 

during the 2019–2024 period to allow interest to be gauged over the course of the National OCS Program 

and allow multiple opportunities for the state and Federal Government to benefit from potential leasing 

activity. Comments state that Arctic OCS leasing, and potential subsequent development activity, has a 

number of ecological and community considerations that must be taken into account, but ultimately have 

important economic, social, and environmental benefits from the state’s perspective, that offshore 

development in Cook Inlet has supplied a substantial amount of Alaska’s community energy needs, and 

that inherent in the statutory direction of sharing benefits across regions is that there is some activity in 

prospective regions that support development when environmental risks can be appropriately mitigated. 

They assert that instead of achieving this balance, the most recently developed BOEM OCS oil and gas 

leasing program for 2017–2022 saw no lease sales in the Arctic and only one within the Cook Inlet area 

for the entire five-year period; and that rather than no leasing, which completely deprives the Nation and 

the state from sharing in the statutorily recognized benefits of development, an equitable balance must be 

established that sees lease sales offered in the Arctic. They note that in Alaska, there is currently little 

offshore commerce or transit, and correspondingly limited support infrastructure; any developments need 

to consider and support the continued ecological use of the OCS by local communities, but there is 

significant state and national interest in establishing a more robust infrastructure network in the Arctic; 

that measured and regulated OCS development is fundamentally consistent with Alaska’s laws and 

essential to support the state’s long-term goals of providing a robust economic and civic base for its 

residents; that TAPS serves as the state’s economic backbone and is a globally impactful piece of the 

national infrastructure; and that identifying new resource potential through leasing and exploration to 

support its continued efficient operation is one of the foremost goals of the state. Finally, they state that 

the presence of the existing extensive oil and gas infrastructure on the North Slope further supports the 

state goal of OCS activity that increases Alaska’s employment opportunities and supports the Nation’s 

export of energy to partners and allies around the world. 

The Bering Sea Elders Group and Association of Village Council Presidents requests BOEM exclude the 

Norton Sound, St. Matthew-Hall, Navarin Basin, Aleutian Basin, and St. George Basin planning areas 

from consideration, while the Olgoonik Corporation supports the inclusion of the Chukchi and Beaufort 

seas in the National OCS Program. The Bristol Bay Native Association requests the North Aleutian 

Basin be excluded, while Arctic Iñupiat Offshore, LLC supports inclusion of the Arctic offshore area, and 

the Arctic Slope Regional Corporation supports inclusion of the Cook Inlet Planning Area. The Native 

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Village of Shishmaref and Savoonga recommend exclusion of the Hope, Norton, St. MatthewHall, and 

Navarin Basin planning areas. Comments were generally supportive of some activity, recognizing the 

economic benefits, but supported exclusion of some areas from leasing consideration to protect their 

subsistence culture, while others opposed lease sales in the Arctic Ocean. See Appendix A of this 

document for comment summaries from tribes and tribal organizations’ comment letters. 

9.2.3 Pacific Region States 

The Governors of California, Oregon, and Washington express their strong opposition to the inclusion of 

any new proposed oil and gas lease sale off their shared coast. The states’ residents comment that there is 

a looming catastrophe of climate change that requires the Nation to move away from fossil fuel 

consumption to a more prosperous, sustainable and clean energy economy. The states played a leadership 

role in the establishment of the U.S. Climate Alliance—a coalition of states committed to achieving the 

U.S. Government’s prior goal of reducing CO2 emissions by 2025. 

Washington State Departments of Ecology, Natural Resources, and Fish and Wildlife oppose the 

inclusion of areas adjacent to Washington in the Washington/Oregon Planning Area because they have 

significant concerns about the added risks and impacts on ocean and community resources that would 

result from oil and gas leasing and development in their offshore waters; that oil and gas leasing, 

exploration, and production on the OCS is inconsistent with Washington State’s laws, policies, and goals; 

that Washington State law prohibits oil and gas exploration, production, and drilling in the state’s marine 

waters; and that the Revised Code of Washington (RCW) 43.143.010 and RCW 90.58.160 establishes 

state policies guiding ocean management, which are currently included as part of Washington’s federally 

approved CZM Plan, including prioritizing ocean uses that do not adversely impact renewable resources 

over those that have adverse impacts on renewable resources, conserving fossil fuels, and protecting 

existing ocean uses and ocean resources from likely long-term significant adverse effects, and creates a 

framework for developing marine plans for Washington’s waters, including addressing potential for 

marine renewable energy (RCW 43.372). 

Oregon Governor Brown’s Energy Policy Advisor submitted comments on her behalf, stating that the 

state had supported the Congressional moratorium on the west coast since 1990 and had a long history of 

opposing efforts to lease for oil and gas in Oregon OCS waters; that State laws and policies prioritize 

long-term use and protection of renewable resources; that Oregon’s various ocean-related plans, including 

its CZM Plan, are guided by these state laws and policies; that in 2010, the state passed a law prohibiting 

oil and gas leasing in the Oregon Territorial Sea; and that Oregon is opposed to the inclusion of any 

Oregon OCS lands in the 2019–2024 Program. 

The California Attorney General expresses strong opposition to inclusion of any California planning areas 

in the new National OCS Program and states that USDOI last conducted a sale for Federal tracts offshore 

California in 1984, and USDOI last included California planning areas in the 1987–1992 Program, the 

lack of leasing of areas offshore California has not posed an obstacle to the development of plentiful 

supplies of domestic oil and gas, and that the Attorney General is not aware of any evidence that the oil 

and gas industry has significant interest in again attempting to explore and develop offshore California. 

The letter further states that the industry has shown this lack of interest in several ways and that the major 

oil companies that leased tracts offshore California in the 1980s have largely given up their leases and 

operations. The letter states further that any company seeking to develop offshore of California would 

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also face a challenging regulatory environment, the California Coastal Commission implements 

California’s federally approved coastal management program and is thus the California state agency with 

regulatory authority over offshore leasing, exploration, and development and production, and that USDOI 

will have to determine that it is conducting lease sales for areas offshore California in a manner that is 

fully consistent with the state’s CZM program, and lessees also will have to certify that their activities are 

consistent with the program. The Coastal Commission has articulated in the past that it is difficult for it 

to understand how it could find that construction and operation of new hazardous infrastructure both 

offshore California and along California’s coast is consistent with the CZM program. The Attorney 

General notes that many local coastal governments have expressed their opposition to onshore support 

facilities. 

The California Coastal Commission steadfastly opposes any new leasing in “frontier” areas of the OCS, 

stating that activities in undeveloped areas off California would require new platforms, offshore and 

onshore pipelines, and other infrastructure that would likely cause significant adverse effects on coastal 

resources. The letter states that producing oil and gas in these areas could have significant, long-term, 

and far-reaching effects on marine and coastal wildlife, commercial fishing, wetlands, ocean and beach 

users, and coastal tourism, additional offshore oil production increases the risk of an oil spill occurring 

and potentially causing devastating state-wide environmental and economic impacts, the expanded use of 

fracking and other well-stimulation treatments could result in chemical discharges that harm marine 

resources, producing oil and gas also results in significant emissions of carbon pollution (GHGs), thereby 

contributing to climate change and rising sea levels, all of which threatens many of the resources integral 

to the California coast, and that new onshore infrastructure and facilities to support offshore oil and gas 

development could have adverse impacts on water quality, agricultural lands and uses, recreation, 

environmentally sensitive habitat areas, scenic vistas, and archaeological resources. 

The California Fish and Game Commission passed a resolution on June 22, 2017, supporting the 

prohibition of oil and gas leasing in Federal waters off California. 

The California State Lands Commission opposes any new oil and gas leasing in the Pacific OCS because 

the Commission believes that such development poses a threat to California’s ocean and marine 

environment and economy. The Commission manages oil and gas resources in state waters. They state 

that a new lease has not been issued since 1968. 

Hawaii Governor David Ige recommends the exclusion of the waters off Hawaii in the National OCS 

Program. He states that there are no indigenous oil and gas resources and the state lacks an OCS.41 The 

governor notes that the state looks to its natural resources—wind, solar, geothermal, and the possibility of 

renewable energy resources from offshore wind and ocean wave resources—to assist in achieving its goal 

of generating 100 percent of Hawaii’s energy in the electricity sector from renewable energy resources by 

the year 2045. 

Blue Lake Rancheria, Habematolel Pomo of Upper Lake Tribe, San Luis Rey Band of Mission Indians, 

Santa Ynez Band of Chumash Indians, Scotts Valley Band of Pomo Indians and the Northern California 

41 As noted in Chapter 4, administratively, the Pacific Region includes the State of Hawaii. However, for the 

National OCS Program, and, in particular, DPP analysis purposes, the Pacific Region only includes the four 

planning areas off the U.S. west coast. 

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Tribal Chairmen’s Association strongly support the exclusion of all Pacific Region areas excluded in the 

current Program in perpetuity, and strongly oppose leasing any areas offshore Northern California and 

areas along the central coast. The Coquille Indian Tribe identified the importance of tourism and fishing 

along the southern Oregon coast, while expressing concern for leasing areas offshore of Coos and Curry 

counties, and the need for formal government-to-government consultation. 

The Makah Tribal Council also recommends exclusion of the Pacific Region, stating that it is a traditional 

use area that would need a comprehensive risk assessment and response plan. The Kashia Band of Pomo 

Indians of the Stewart’s Point Rancheria strongly opposes leasing the area expanse from Duncan’s 

Landing to the mouth of the Gualala River, and provided a list of specified areas BOEM should consider 

during potential impacts analysis including environmental resources, subsistence activities, and mitigation 

of potential oil spill risk. The Confederated Tribes of Coos, Lower Umpqua & Siuslaw Indians especially 

emphasize exclusion of the Oregon coast. The Federated Indians of Graton Rancheria expressed concern 

for potential marine environment damage. Comments were generally opposed to all leasing activity, 

recognizing the environmental and cultural impacts. See Appendix A of this document for comment 

summaries of tribes and tribal organizations’ comment letters. 

9.2.4 Gulf of Mexico Region States 

The Chair of the Texas Railroad Commission, the agency with oversight of the Texas energy industry, 

conveys strong support for a National OCS Program that includes all 26 planning areas. His letter states 

that excluding areas at the outset and in the absence of critical environmental analysis would be premature 

and potentially harmful to efforts to enhance American energy security. Two Commissioners of the 

Commission also support a robust leasing program that includes all 26 planning areas. 

The Louisiana Department of Natural Resources, Office of Coastal Management, supports exploration 

and development throughout OCS waters. In their opinion, domestic expansion will present positive 

opportunities for American workers and business owners, while benefitting the entire United States. 

However, they state that the coastal area of Louisiana continues to suffer adverse cumulative and 

secondary impacts from these activities, and that Louisiana has endured wetland losses at an alarming rate 

throughout the 50-year history of BOEM lease sales in the GOM and continues to do so today. The 

Office does not believe Louisiana has received adequate habitat mitigation commensurate with these 

impacts. They believe that the upcoming OCS leasing program presents a fresh opportunity to rectify the 

situation and develop a protocol for addressing these impacts, and that at this early stage in lease sale 

planning, they believe that it is appropriate for BOEM to embrace its role as steward of these Federal 

resources and address the secondary and cumulative impacts resulting from these OCS activities. 

Governor Ivey stated that the State of Alabama has a keen awareness of the importance of oil and gas 

production to the state’s economy and national security and has long supported a balanced and reasonable 

leasing program, contingent on all OCS activities adjacent to Alabama being carried out in compliance 

with state laws, rules, and regulations and consistent with its CZM program. Alabama states that it has 

long requested protection for live bottom habitats, pinnacle reefs, chemosynthetic communities, and other 

sensitive environments, and has long opposed leasing within 15 miles off Baldwin County to minimize 

visual and other impacts. The governor urges that all unleased areas of the OCS be included in the DPP. 

The governor emphasizes that revenues should be shared with adjacent states. She supports the existing 

revenue sharing program but believes it should be expanded and enhanced. 

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9.2.5 Atlantic Region States 

The Florida Department of Environmental Protection coordinated a review by several state agencies. The 

Department stated that Florida’s coastal and offshore areas have high environmental and economic value 

not only for Florida, but also for the Nation, that several areas offshore Florida are considered an essential 

component for developing and sustaining military readiness, that the state remains concerned about the 

effects of OCS oil and gas activities on marine and coastal environments and the sensitive biological 

resources and critical habitats associated with them, as well as the military activities critical to the 

Nation’s security. The state argues that as BOEM proceeds with the development of a proposed plan for 

oil and gas activities, the long-term protection of Florida’s sensitive coastal and marine resources should 

be of paramount concern. Enclosed were more detailed comments from the Florida Department of State, 

Florida Fish and Wildlife Conservation Commission, Florida Geological Survey, and Treasure Coast 

Regional Planning Council. 

The Georgia Department of Natural Resources, on behalf of Governor Dial, supports environmentally 

sound efforts to increase the domestic oil and gas reserves of the United States and is of the position that 

there are several issues that must be considered in any leasing plan involving Georgia offshore waters: 

1) the physical environment; 2) the biological environment; and 3) the socioeconomic environment of the 

state. The commenter included a more detailed discussion of these categories of impact in the Technical 

Addendum to the letter. In summary, the state supports the preparation of a National OCS Program 

provided that all relevant environmental and societal issues are fully addressed, and states that given the 

current need for greater energy security in the United States, the state supports an effective state and 

Federal partnership that explores options for new energy resources. 

The Governor of North Carolina states that drilling threatens the state’s coastal economy and environment 

and therefore requests that the current leasing plan be maintained with the prohibition of oil and gas 

leasing off the North Carolina coast. The governor included a comment letter from the Secretary of 

Environmental Quality that reiterated the state’s opposition and presented a summary of the unique 

geographic and marine environments and the socioeconomic, legal, and policy frameworks that must be 

considered in the evaluation of including the waters off the state’s coast. In the attached letter from the 

Department of Environmental Quality, it was noted that the State has had a CZM program since 1974 and 

that energy policies first adopted in 1979 were codified as law in 2010 and approved as enforceable 

policies by NOAA in 2016, and include lists of the types of nearshore and offshore sensitive areas to be 

avoided, required mitigation where impacts cannot be avoided and restoration of sites when facilities are 

abandoned. 

The North Carolina Lieutenant Governor (and Chair of the North Carolina Energy Policy Council) writes 

in support of including the Federal lands off the coast of North Carolina for oil and natural gas 

exploration. The Energy Policy Council, which is the central energy policy planning body of the state, 

recommended in its last comprehensive report that “harnessing offshore energy reserves in an 

environmentally safe and responsible manner will lead to greater economic prosperity for North 

Carolina.” The commenter encourages legislative efforts to promote revenue sharing with coastal energy 

states and states that to bring offshore energy development to North Carolina, the state will need to 

develop onshore infrastructure, ports and inlets, and regulatory programs as well as obtain local support. 

He states that without revenue sharing, many coastal residents feel that they are being asked to bear all the 

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costs and risks without reaping any of the rewards. He acknowledges that offshore production could 

bring economic benefits and thousands of jobs to North Carolina’s, as well as our Nation’s economy and 

that this would strengthen the U.S. economic security and energy independence. 

The Governor of Virginia states his understanding that BOEM is considering for inclusion in the new 

National OCS Program all unleased areas off the OCS, including unleased areas off the coast of Virginia. 

As the state commented during the process to develop the 2017–2022 Program, a primary concern that 

must be satisfied for Virginia to be included in the leasing area is a revenue sharing agreement between 

participating Atlantic coastal states and the Federal Government. The Governor adds that because the 

parties are no closer to resolving this issue, Virginia requests that the Commonwealth not be included in 

the new National OCS Program. 

The Virginia Lt. Governor’s Chief of Staff stated that the Lt. Governor’s position had not changed from a 

February 26, 2016, letter submitted to BOEM in which the Lt. Governor asked that Virginia be excluded 

from the 2017–2022 Program. The Lt. Governor cited effects on climate change, military and NASA 

assets, tourism, a growing seafood industry, and the uncertainty over royalty disbursements. 

The Maryland Department of Natural Resources opposes opening up the Mid-Atlantic OCS lease area for 

oil and gas exploration and development activities as part of the 2019–2024 National OCS Oil and Gas 

Leasing Program. From both an economic and environmental perspective, Governor Hogan’s 

administration is opposed to offshore oil and gas drilling off Maryland’s coast and has serious concerns 

about seismic surveys and testing in the Atlantic Ocean. The letter states that over the past several years, 

Maryland has worked together with MidAtlantic local, state, Federal, and tribal partners, as well as 

citizens, to begin charting a future for the ocean that ensures a healthy ocean ecosystem and supports 

sustainable ocean uses. Maryland states that it is concerned about the threat of oil spills and their direct 

and indirect effects on coastal and bay ecosystems and economies, and that these risks raise significant 

questions about the cost and benefit of pursuing oil and gas leasing in sensitive coastal environments. 

The Department urges the exclusion of the Atlantic OCS lease areas from the 2019–2024 planning 

program. 

The Governor of Delaware is opposed to any future leasing, exploration, development or production of oil 

and gas in the Atlantic Ocean. The letter states that reinitiating plan development at this time is an 

inefficient use of government resources and merely politicizes what should be a data-driven and public 

process. They state that marine habitats and the species that rely on them are nationally shared resources 

that do not adhere to federally designated offshore boundaries. Of particular importance to the state are 

the canyons that extend from off Massachusetts to North Carolina. 

The New Jersey Department of Environmental Protection, on behalf of Governor Chris Christie, strongly 

opposes any waters off its coastline (North and Mid-Atlantic) being considered for inclusion in this 

leasing program. They state that New Jersey has consistently opposed any industrialization of its coast, 

including the exploration and development of offshore oil and natural gas resources, and into any portion 

of the Atlantic Ocean that could negatively impact New Jersey’s natural resources or coastal 

communities. The state comments that it considers that the risk of adverse impacts on its marine waters 

and the species that depend on them is unacceptable. 

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New York’s Environmental Protection Bureau submitted comments on behalf of the state’s Attorney 

General, focusing on their position that BOEM must address the potential climate change implications of 

development of a new National OCS Program. The commenter believes that in preparing a new National 

OCS Program, the requirements of Section 18 of the OCS Lands Act dictate full consideration of whether 

expanded oil and gas on the OCS would interfere with the U.S.’s ability to mitigate the substantial 

adverse societal impacts of climate change. 

The New York Department of State, Department of Environmental Conservation, and Energy Research 

and Development Authority commented jointly, and cite the state’s energy plan developed under the 

direction of Governor Andrew Cuomo that seeks to grow the state’s clean energy industry, reduce 

emissions that contribute to the frequency of extreme weather events, and manage its coastal waters in a 

manner to mitigate potential harm to communities and environment. The commenters’ position is that 

any renewed consideration of oil and gas development off the coast of New York would disrupt existing 

plans to develop clean offshore wind generation and harm the state’s continued efforts to protect and 

preserve the quality of life for New Yorkers. They state that activities associated with any OCS oil and 

gas exploration and production offshore would have reasonably foreseeable effects on New York’s 

coastal uses and natural resources that go beyond discrete siting concerns and threaten New York’s 

coastal economy. They state that these effects pertain to enforceable coastal policies of New York’s 

federally approved CZM program and would be subject to Federal consistency review, and that the 

review would include State Coastal Policy 29, which specifically addresses the diversity of OCS uses and 

resources important to New York State’s coastal and statewide economy. Of particular concern to them 

are potential effects that oil and gas activities could have on the current and future conditions of the 

state’s energy economy and ocean environment, including the potential for oil spills and contamination. 

The Connecticut Department of Energy and Environmental Protection commented that the state has 

consistently opposed the inclusion of the North Atlantic in a National OCS Program. They state that if 

the North and MidAtlantic were to be included, the state‘s laws, goals, and policies as contained in its 

CZM Act must be addressed, which include a list of resources and uses typifying the coastal environment 

and a description of the adverse impacts on such resources and uses that could result from development 

activities. The state supports the development of alternative energy sources and actions aimed at 

conserving fossil fuels. 

The Massachusetts governor states that the Commonwealth does not support inclusion of areas of the 

North Atlantic adjacent to or affecting Massachusetts, and that neither exploration nor leasing has been 

justified in the North Atlantic for more than three decades and that model still holds true. The governor 

supports wind energy in the OCS off Massachusetts and BOEM’s coordination of such efforts. 

Because of state concerns with the potential risks it poses to the Massachusetts economy and its coastal 

ecosystem, the Commonwealth’s Attorney General strongly opposes opening up any portion of the 

Atlantic—or any other new ocean areas—to oil and gas leasing, stating “Our country does not require 

expanded offshore fossil fuel extraction to meet our future energy needs, nor can we afford the increased 

greenhouse gas emissions that would result from such development. Sea level rise from climate change 

already threatens our coastal communities.” The comments urge BOEM to withdraw its notice, 

discontinue preparation of a new five-year plan, and maintain the recently finalized plan, which forecloses 

leasing in any new areas of the Gulf and Arctic Ocean, and in the entire Atlantic and Pacific OCS. 

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The Gullah/Geechee Nation stated opposition to leasing all areas off of North Carolina, South Carolina, 

Georgia, and Florida. 

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Chapter 10 Assurance of Fair Market Value 

Section 18(a)(4) of the OCS Lands Act requires receipt of FMV from OCS oil and gas leases: “Leasing 

activities shall be conducted to assure receipt of fair market value for the lands leased and the rights 

conveyed by the Federal Government.” Furthermore, the OCS Lands Act states that the OCS is a “vital 

national reserve held by the Federal Government for the public, which should be made available for 

expeditious and orderly development, subject to environmental safeguards, in a manner which is 

consistent with the maintenance of competition and other national needs” (43 U.S.C. § 1332 (3)). 

While the OCS Lands Act mandates that BOEM ensures receipt of “fair market value,” the Government 

Accountability Office has issued reports in recent years that refer instead to “fair return.” FMV was 

operationally defined by the report entitled Procedures for OCS Bid Adequacy Including the Final Report 

of the OCS Fair Market Value Task Force (USDOI 1983) as related to the adequacy of the level of the 

high bid offered for a lease with given fiscal terms, not to the design or setting of the fiscal terms 

themselves. In contrast, the term “fair return” fully considers whether all aspects of a lease sale, including 

fiscal terms, are likely to give an appropriate share of revenue to the government. This chapter considers 

both the specific procedures designed to ensure FMV for a specific lease as well as the broader 

consideration of fair return. 

To secure and maintain public trust in utilizing OCS resources, BOEM uses an established set of criteria, 

described herein, that ensure the provision of adequate returns to the general public for the OCS lease 

rights issued. The assurance of FMV is a multi-phase process including National OCS Program-level 

analysis, lease sale-level analysis, and, finally, analysis conducted prior to the issuance of an individual 

lease following a lease sale. 

In carrying out its FMV responsibilities at the National OCS Program development stage, BOEM has 

adopted screening criteria that recognize the importance of considering the value of waiting to lease. 

BOEM considers the importance of timing using a hurdle price analysis. This analysis, described in 

detail in this chapter, identifies whether each planning area would provide greater value in including it in 

the 2019–2024 Program or delaying leasing until a future National OCS Program. Some other factors 

that could affect the value of waiting to lease are discussed qualitatively in Section 10.1.1. 

Another component of assuring FMV, pertinent for both the National OCS Program and individual lease 

sale stages, is the consideration of the size(s) and frequency of lease sales. Both size and frequency can 

affect FMV because they can affect competition and pace of leasing. The size of a lease sale is 

determined based on several factors, including FMV considerations, economic efficiency, need for 

orderly development, environmental sensitivity, marine productivity, and subsistence use. BOEM 

considers FMV during preparation and execution of the National OCS Program. Further discussion is 

provided in Section 10.3.2, Fiscal and Lease Terms. 

Following the size, timing, and location decisions formulated at the National OCS Program development 

stages, BOEM assesses other FMV-related components, such as bidding systems and fiscal and lease 

terms, at the lease sale stage to help ensure that the public receives a fair return when leasing resources. 

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Regulations allow BOEM flexibility in tailoring these components to assure FMV in each program area at 

the lease sale stage. The stages and components of the FMV analysis are described herein. 

The final assurance of FMV involves assessment of the bonus bids submitted for leases, which occurs for 

each individual lease receiving a bid shortly after the lease sale and prior to lease issuance. The rules and 

procedures for this process were revised in 2016 and are available at http://www.boem.gov/ 

Fair-Market-Value/. These FMV assessments of the cash bonus bids are also referred to as 

determinations of bid adequacy, and they follow a two-stage procedure. The first phase involves 

BOEM’s assessment of the block’s geologic and economic viability. In the second stage, the 

government’s assessment of the high bid is based on a stochastic simulation model of the activities, 

results, and outcomes anticipated to occur post-sale related to exploration, development, and production 

of the oil and gas resources potentially contained on the applicable tract. Therefore, the bid adequacy 

determinations are in part based on forecasts of future prices and discovery volumes rather than on the 

actual value of the oil and natural gas eventually discovered and produced. Furthermore, consistent with 

the private formulation of the cash bonus bids, these determinations take into account existing statutory 

and regulatory conditions such as drilling requirements within the lease terms that could restrict lessee 

flexibility. 

10.1 TIMING OF OCS LEASE SALES AND RELATED ACTIVITIES 

In determining whether an area should be included at this National OCS Program stage, BOEM evaluates 

broad area-specific considerations, including a comparison of market prices to the calculated hurdle prices 

for oil and natural gas. However, in making the ultimate decisions on size, timing, and location, many 

other factors are considered, including coastal state, industry, and stakeholder interest as well as 

environmental factors (see Chapter 2). 

The value of the OCS resources and associated leases is affected by the timing of leasing. Because OCS 

leases have fixed primary terms (described in Section 10.3.2) as required by the OCS Lands Act, lessees 

planning to explore and initiate development on an economic prospect must do so within that primary 

term. However, in certain cases, it could theoretically be better for the lessee to wait longer to explore 

and develop, but this cannot be accomplished if it requires waiting beyond the primary term. This 

situation could arise, for example, if the price of oil or gas were trending downward, but showing signs of 

recovery after the primary term. In this situation, the lessee cannot wait for prices to rise before 

exploration and development because the primary term would be nearing expiration. However, waiting 

could be in society’s (as well as the lessee’s) interest because the resources would be worth more. In this 

case and in others, it is conceivable that greater value could be realized by waiting longer to lease in the 

first place, given the fixed length of the primary lease term. 

To account for the possibility of situations where the variation in future resource prices implies that 

exploration and development within the primary term of some leases could be privately profitable but not 

socially optimal, a hurdle price screen is employed. A lease could be privately profitable at a certain 

price, but by waiting to lease, bring a greater value to society. Here the social value is similar to that 

calculated in Section 5.3. Social value is the gross revenue of the resources less the private and social 

costs of extracting the resources. This is explained more fully in Section 10.1.2. 

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The hurdle price screen is conducted at the National OCS Program stage to determine whether it is likely 

that there are any geologic fields within a planning area for which a lease sale in this National OCS 

Program would provide a greater social value compared to delaying and offering those fields for sale in a 

future National OCS Program. In this context, a hurdle price is defined as the planning area-specific, 

weighted BOE price above which immediate exploration of at least one undiscovered prospect as 

identified by BOEM’s resource assessment is the timing option with the greatest social value. Further, 

the hurdle price for the planning area is compared to actual prices prior to each lease sale held under the 

National OCS Program. The hurdle price is one consideration, subject to uncertainty about future price 

projections, used to evaluate an area before a lease sale and should be considered in conjunction with 

other factors. 

The logic of the argument that the greatest value can be obtained with consideration of the optimal timing 

of leasing extends beyond the volatility of price factor to include other areas of uncertainty, as discussed 

in Section 10.1.1, Information and Uncertainty. 

10.1.1 Information and Uncertainty 

At the time of lease issuance, uncertainty exists regarding not only future prices, but also risked resource 

endowments, capital and operational costs, available technologies, environmental and social costs, and the 

prevailing post-sale regulatory and legal environments. An objective of both the government and industry 

is to manage the risks associated with these uncertainties. With its fiscal terms, the government, as the 

lessor, transfers most of the fiscal risk to the lessee in exchange for an upfront bonus bid, rentals on nonproducing acreage, and a royalty interest if the lease enters production. The lessee assumes virtually all 

of the cost risk. Other risks are managed through employment of industry best practices, legal liability, 

and enforcement of safety and environmental laws and regulations governing OCS operations. 

All of these considerations could be reflected in the FMV of the lease. The analysis described in this 

chapter avoids an overly narrow interpretation of fair “market” value, and considers aspects of the value 

of leasing that could be viewed as “social value,” extending beyond the value that would be observed in 

private markets if the latter do not fully reflect externalities. Bearing that in mind, this section explains 

how decisions regarding the timing of leasing, made at the appropriate points during preparation and 

conduct of the National OCS Program, could reflect consideration of how uncertainty and information 

might evolve. 

10.1.1.1 Option Value 

Option value is defined as the value of waiting to make an irreversible investment until critical new 

information arrives. In general, option value can be an element of the FMV of a lease, and its magnitude 

and significance is directly affected by components of uncertainty and information, or lack thereof. In 

designing the National OCS Program, BOEM provides the Secretary with information relevant to 

decisions on the size, timing, and location of lease sales. Public comments received on prior National 

OCS Programs have suggested that USDOI consider option value while performing its size, timing, and 

location analysis to fulfill the FMV statutory requirement. The hurdle price analysis considers the 

uncertainty of oil and gas prices and the expected hydrocarbon endowment. This section discusses 

nonmarket factors that are reflected in option value in a broad sense. 

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When uncertainties exist, having the option to delay activities creates value as more information can be 

revealed and acted on in the future. However, once an action is taken, the presence of uncertainty is 

known to reduce the net benefits of a project because the action eliminates the value of option of waiting 

to make that decision (Arrow and Fisher 1974). In connection with socially optimal OCS oil and gas 

development, the gist of option value is that a decision regarding whether to use an oil and gas asset can 

be modeled as a perpetual call option (Davis and Schantz 2000). From the government’s perspective, 

OCS oil resources are a perpetual call option in that the government has the right, but not the obligation, 

to offer OCS areas for lease at any time in the future (i.e., the option does not expire). The decision 

regarding exercising the option at a particular time can reflect price volatility as well as emerging 

information about resources, costs, and risks when the social value of the option is in question. 

The broad form of option value here includes what can be termed “quasi-option value.” The concept of 

“quasi-option value” was identified by Arrow and Fisher (1974) and is defined as the “benefit associated 

with delaying a decision when there is uncertainty about the payoffs of alternative choices and when at 

least one of the choices involves the irreversible commitment of resources” (Freeman 1984). While 

traditional option value focuses on the value of an action now versus in the future, quasi-option value of 

an action is based on uncertainty and the value of information that can be gained now versus in the future. 

An important distinction in quasi-option value is what is uncertain and how those uncertainties are 

resolved. There are uncertainties about both the benefits of development and the benefits of preservation 

when choosing to offer or withhold an OCS area for oil and gas development. In the case of the uncertain 

preservation benefits, these uncertainties will likely only be resolved through receipt of additional 

information. This is defined as “independent learning” as the uncertainties can be resolved without 

development of the oil and gas resource (Fisher and Hanemann 1987). However, in the case where many 

of the uncertainties revolve around the benefits of development, these uncertainties are likely only 

resolved with exploration and development of the oil and gas, demonstrating “dependent learning.” 

In their work on option value, Fisher and Hanemann (1987) specifically discuss the example of offshore 

oil leasing, acknowledging the “dependent” nature of uncertainties given that the largest uncertainty lies 

in estimating the quantity of oil and gas resources, which can only be resolved, and then only partially, by 

exploratory well drilling. Therefore, if the desired information regarding environmental and social costs 

is, or can be, obtained without drilling, which by nature embodies some degree of risk, then it is 

“independent” information, and the case for significant option value and exclusion is strengthened. 

Conversely, if there is no way to obtain information other than by conducting exploration activities, then 

this aspect of option value is ambiguous. As described by Fisher and Hanemann (1987): 

It surely requires no algebra to show that, if the information about the consequences of an 

irreversible development action can be obtained only by undertaking development, this 

strengthens the case for some development. The practical importance of this observation 

depends on the answers to two empirical questions. Is it true that the information can be 

obtained only by undertaking development? How much development is required in order 

to obtain the information? 

To answer these questions, we must first consider the nature of the information being sought based on the 

many uncertainties surrounding OCS oil and gas development and how these uncertainties can be 

resolved. 

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10.1.1.2 Considering Uncertainties for the National OCS Program 

To determine whether the possibility exists for significant option value associated with delayed leasing, 

BOEM considers the uncertainties surrounding OCS activities and how these uncertainties could impact 

the value of OCS acreage. Resolving uncertainties can reduce risk and greatly change the value of a lease 

and corresponding societal value. The following sections discuss the uncertainties that can affect the 

potential value and possible risks of OCS oil and gas and how these uncertainties could be resolved. 

Major uncertainties surrounding oil and gas development are discussed in context of independent and 

dependent learning. Many include components of both, and these uncertainties tie to components of the 

net benefits analysis discussed in Section 5.3, Net Social Value. 

The discussion of uncertainties and option value must always consider the pyramidal structure of the 

National OCS Program development and lease sale processes. The National OCS Program development 

process begins by considering all leasing areas, and the potential areas are winnowed down into what is 

ultimately the final lease sale schedule. Program areas can be removed at any stage of the National OCS 

Program development process, but cannot be added back in once they are removed without starting over 

the National OCS Program development process or by an act of Congress. Further, the Secretary has the 

flexibility to cancel a lease sale even after the National OCS Program is approved. Given these 

procedures, to maintain the maximum option value, USDOI may consider retaining Program Options in 

the National OCS Program to potentially hold lease sales in these areas during the five years covered by 

the National OCS Program, should some of the independent information become available. Theoretically, 

omitting any area from the National OCS Program could cause a loss of option value to the government. 

USDOI retains the greatest flexibility, and therefore option value, by including areas in the National OCS 

Program, but it is also true that there can be instances where the Secretary may be justified in excluding 

an entire area from the National OCS Program. These reasons could include the possibility that major 

environmental or comparative studies would not be completed and no new information would be 

available within the span of the National OCS Program. Another reason to exclude an area could be if the 

estimated developmental value of an area is marginal and the probability of generating sufficient 

information to improve its value is negligible, thereby limiting the value of including it in the National 

OCS Program. Excluding very marginal areas also reduces administrative and study costs. 

The Secretary may choose to cancel lease sales if any important informational uncertainties have not been 

satisfactorily resolved at the lease sale stage. Further, the Secretary can consider when important 

information is expected to become available when scheduling the individual lease sales within the 

National OCS Program. 

While it is possible to re-evaluate and cancel sales during the lease sale planning process, it is important 

to be aware of the industry need for predictable and orderly leasing. An intended benefit of the National 

OCS Program lease sale schedule is that a schedule of possible lease sales within the five-year period 

facilitates industry planning, operations, and scheduling, thereby increasing the value of OCS acreage. In 

contrast, a process in which there is no presumption that a lease sale will actually be held as scheduled 

imposes costs on industry and decreases the value of OCS acreage. 

At the National OCS Program stage, no irreversible commitment of resources occurs because, as 

discussed, the Secretary can always choose to cancel a lease sale. For this reason, the lease sale stage is a 

more appropriate place to consider quasi-option value because that is when the irreversible leasing 

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decision is made. However, the National OCS Program stage is where BOEM holistically considers all 

planning areas and therefore it is helpful to discuss the nature of OCS oil and gas leasing and the 

resolution of uncertainty. 

In addition to obtaining FMV for OCS resources, the OCS Lands Act mandates that OCS resources must 

be made available for expeditious and orderly development. The Congressional declaration of purposes 

in the OCS Lands Act Amendments of 1978 states that one of the purposes of the OCS Lands Act is to 

“make such resource[s] available to meet the Nation’s energy needs as rapidly as possible” 

(43 U.S.C. § 1802(2)(A)). An additional purpose is to “encourage development of new and improved 

technology for energy resource production which will eliminate or minimize risk of damage to the human, 

marine, and coastal environments” (43 U.S.C. § 1802(3)). Any decision to delay leasing based on the 

possibility of greater future value must be balanced with the requirement to expeditiously make 

prospective OCS oil and gas resources available. Through the National OCS Program development 

process and lease sale design process, the Secretary can evaluate decisions in conjunction with the OCS 

Lands Act purposes. 

The next subsections consider the many different uncertainties that exist in OCS oil and gas development. 

Most of these uncertainties are discussed qualitatively with reference to the nature of the uncertainty and 

how the uncertainties could resolve themselves over time. This discussion is included because BOEM 

acknowledges the possibility of obtaining additional information that could affect the value of OCS 

resources over time. This value was also recognized by the court in CSE v. Jewell (779 F.3d 588 

(D.C. Cir. 2015)). 42 While discussed, BOEM does not quantify the quasi-option value of each of these 

uncertainties given difficulties in quantifying the informational value of delay and lack of wellestablished 

methods to quantify such considerations.43 BOEM is evaluating existing literature on quantifying the 

informational value of delay and could incorporate these methods in future National OCS Program 

analyses. 

While the majority of the uncertainties are considered qualitatively, BOEM includes a quantitative 

treatment of price and resource uncertainty. These uncertainties are discussed in Section 10.1.2, Hurdle 

Prices, which describes the hurdle price analysis. 

10.1.1.3 Resource Uncertainty 

The fundamental unknown for OCS oil and gas leasing is the uncertainty of the resource endowment (see 

Section 5.3.4). The uncertainty associated with the presence and estimated quantity of oil and gas 

resources can only be fully resolved through lease acquisition and subsequent drilling of OCS acreage. In 

this sense, “dependent learning” is required to resolve uncertainty. Private companies must spend billions 

of dollars to acquire leases and analyze geologic information in an effort to discover and ultimately 

produce new oil and natural gas reserves that are undiscovered. 

42 The court found that “[t]here is therefore a tangible present economic benefit to delaying the decision to drill for fossil fuels to 

preserve the opportunity to see what new technologies develop and what new information comes to light.” CSE v. Jewell, 

779 F.3d 588 at 610 (D.C. Cir. 2015). 43 The D.C. Circuit court upheld BOEM’s qualitative approach to considering option value in CSE v. Jewell, 779 F.3d 588 

(D.C. Cir. 2015). The court found that “Interior acted reasonably in employing qualitative, rather than quantitative, measures of 

the informational value of delay.” BOEM continues to study ways to quantitatively measure the informational value of delay. 

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At this initial stage of National OCS Program development, there is significant uncertainty regarding the 

individual and aggregate volumes of oil and gas that are present on unleased acreage. The Secretary is 

also uncertain about the extent to which these undiscovered resources are commercially viable and when 

those resources that are not currently commercially viable could become so, especially in relatively less 

mature OCS areas and at relatively lower prices. BOEM’s estimates of resources available in each of the 

planning areas are presented in the 2016 National Assessment (BOEM 2016a). A summary of the 

methodology for this assessment is presented in Chapter 5. 

An example of how exploration of an OCS region has changed the knowledge of resource potential is 

provided by experiences in the GOM Region, where estimates of undiscovered oil resources have 

increased dramatically since the discovery of major deepwater oil and natural gas fields. In deep water, 

increases in oil and gas potential have been facilitated by industry’s development of new technology to 

explore for and extract oil and gas resources. In all water depths, the expansion of offshore infrastructure 

and new technology has allowed industry to produce smaller and more geologically complex reservoirs. 

Conversely, exploration also can lead to reduced resource endowment estimates. The Navarin Basin in 

the Alaska OCS is an example of how exploration can render an area less attractive. A resource 

assessment published in 1985 reported that the Navarin Basin Planning Area had an estimated 1.30 BBO 

of mean risked oil volumes, which were much greater than the estimated 0.54 BBO in the Chukchi Sea 

Planning Area (MMS 1985). However, no oil or natural gas pools were discovered from any of the eight 

exploration wells that were drilled in the Navarin Basin Planning Area after a 1983 lease sale resulted in 

163 tracts being leased for $633 million. The subsequent geologic analysis severely downgraded the 

Navarin Basing Planning Area resource estimate to 0.13 BBO in the 2016 assessment (BOEM 2016a). 

There has been little or no subsequent industry interest in this area. 

Conversely, drilling results in the Chukchi Sea Planning Area in 1990 and 1991, new technologies, and 

higher oil prices were key factors leading to the largest lease sale ever in the Alaska OCS, Chukchi Sea 

Lease Sale 193, with 487 tracts leased for $2.66 billion in 2008. The current risked mean technically 

recoverable resource estimates for the Chukchi Sea Planning Area increased by a factor of 30 over the 

1985 estimate to 15.4 BBO, and natural gas increased by more than a factor of 25 to 76.8 Tcf in this 

frontier area. However, after the 2015 drilling season, Shell found resources “not sufficient to warrant 

further exploration” in the explored prospect (Shell 2015). While the aggregate resource estimates remain 

unchanged, this announcement, in conjunction with other market factors, led to a decline in industry 

interest and leased acreage held in the region. However, future drilling on other prospects, higher oil and 

gas prices, or other new information could have a great impact on the level of interest in the region. 

Future exploration in this area will further decrease the uncertainties regarding its oil and gas resource 

potential. 

While drilling is the most definitive way to reduce resource uncertainty, it is also possible to reduce 

uncertainty through improved knowledge about the resource potential using seismic surveys and 

exploration and development activities on nearby leases. Information from activities on nearby leases can 

only be obtained in areas where leasing already exists.44 

44 This is analyzed in the paper by Rothkopf et al. (2006), Optimal Management of Oil Lease Inventory. 

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Because resources form the basis for the net benefits analysis, changes in perceptions of resource 

endowments could greatly change the ranking of the planning areas. The largest potential for resource 

growth or decline would be in the areas where the least exploration has occurred. However, it is unlikely 

that substantial information could be reliably compiled before some development has occurred. This is an 

example of dependent learning. 

10.1.1.4 Capital and Operating Cost and Extractive Technology Uncertainty 

Companies operating on the OCS face uncertainty regarding future capital and operating costs. This 

uncertainty is greater in frontier planning areas because much is still unknown about the costs of 

operating in those areas. In the GOM, lessees have had decades of experience and there is generally less 

cost uncertainty. Costs cannot be known with certainty in frontier areas until exploration and 

development begin. 

A portion of the cost uncertainty is driven by changes in resource prices. Increased oil prices create 

additional competition for existing drilling rigs and investment dollars from other parts of the world, 

which raises the cost of exploration, development, and production. Through internal modeling efforts and 

validation with external sources, BOEM has estimated that costs increase at roughly half the rate of 

increase in resource prices. In addition to price, capital and operating costs are driven by changes in 

international demand for oil and natural gas extraction resources. For example, international oil company 

interest in resources off the coast of Mexico could impact OCS capital and operating costs over the next 

few years. This is because oil and gas opportunities in the southern portion of the GOM could increase 

competition for oil and natural gas investment dollars and drive up demand for rigs and skilled workers. 

According to the logic of option value, value can be enhanced by delay of action in a case where costs are 

currently deemed to be high, with a probability of decreasing in the future. In the case of OCS oil and 

gas, there is not a reliable method to know, or to predict, whether costs will decrease in the future. In 

addition to capital and operating costs, technical challenges during the exploration and delineation of a 

particular prospect can result in drastic cost changes. For example, unexpected challenges can greatly 

influence project economics, such as drilling a well into a high-temperature/high-pressure reservoir or 

natural events such as hurricanes. This further demonstrates dependent learning. 

Uncertainties surrounding the magnitudes of capital and operating costs also influence the net benefits 

estimates for each planning area. Because the capital and operating costs are inherent in calculating the 

NEV (a major component of a planning area’s net benefits calculation), changes in costs could alter the 

estimate of NEV in each of the planning areas. 

Over time, innovative technology could become available to more efficiently or safely extract oil and gas 

resources, and/or reduce risks associated with extraction. Well control and containment technologies are 

improving operators’ ability to mitigate damages of a well control incident through closing the well, 

capturing the flow, or assisting in clean-up operations. This further illustrates the concept of dependent 

learning, which is an element in the option value calculus but is oftentimes not considered in comments 

received regarding the importance of taking into account option value concepts in National OCS Program 

formulation. 

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10.1.1.5 Environmental and Social Cost Uncertainty 

Additional environmental information is always becoming available. As part of the National OCS 

Program decision on size, timing, and location, the Secretary considers the available environmental and 

social cost information. 

All of the environmental or social cost estimates in BOEM’s analysis, particularly the impacts estimated 

in the OECM, are subject to uncertainty and future revision. A range of uncertainty around any of the 

point estimates provided can occur. Viewed from an analytical perspective, the situation is similar to that 

of resource estimates; there is some probability that environmental and social costs might be smaller or 

greater than the point estimates provided, and that directly affects the magnitude of the expected option 

value. 

In contrast to resource estimates, most environmental impacts can be mitigated, remediated, or otherwise 

compensated. However, even with mitigation measures in place, certain impacts could be deemed as 

significant and irreversible. For many years, environmental scientists and economists have examined the 

risks of irreversible impacts, and some researchers have applied real options theory to irreversible issues 

such as species extinction and climate change. 

Certain studies consider the uncertainty of the chances of oil and gas exploration and development 

causing species extinction, and the uncertainty of the value of a given species. Abdallah and 

Lasserre (2008) assert that logging in a certain forest might cross an ecological threshold leading to 

caribou extinction. Option value models formalize the intuition that logging is not beneficial unless the 

implied risk is “low enough.” The value lost if a species becomes extinct is also uncertain. As described 

by Kassar and Lasserre (2002), biodiversity relates to a “portfolio” of future uses for species. 

Another study specifically considered the amenity value that would be lost with oil and gas development 

in the Arctic National Wildlife Refuge. Conrad and Kotani (2005) estimate a “trigger price” for oil that 

would justify the loss in amenity value if development were allowed in the region. In theory, a similar 

approach could be applied to OCS leasing. BOEM is continuing to evaluate methods in which an 

amenity value could be incorporated into future hurdle price analyses. 

The relatively few studies that apply real options concepts to possibly irreversible environmental impacts 

from oil and gas activities demonstrate the serious difficulty of assessing these risks. It is not hard to 

envision the broad outlines of a real options model of environmental impact; but it is surpassingly 

difficult to specify and estimate a useful, empirical model of that type. 

BOEM’s Environmental Studies Program (ESP) recognizes the need for new environmental information 

and has funded more than $1 billion in research throughout its 40-year history, covering physical 

oceanography, atmospheric sciences, biology, protected species, social sciences and economics, 

submerged cultural resources, and environmental fates and effects. Information developed by BOEM’s 

ESP and other sources is incorporated in environmental analyses conducted by BOEM and builds the 

foundation for science-based decision making throughout the National OCS Program development and 

leasing stages. 

The ESP recognizes the different needs for information in each of the OCS regions and tailors the studies 

accordingly. In Alaska, the ESP focuses on many topics including protected species, physical 

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oceanography, wildlife biology, subsistence and traditional knowledge, economic modeling, oil spills, 

and Arctic resources. Research in the Pacific region focuses on platform biology, an intertidal monitoring 

program, and renewable energy development. In the GOM, studies focus on a wide range of subjects 

including oil spill modeling and deepwater oceanographic processes, archaeological and biological 

research, deepwater corals and habitat mapping, protected species observations and monitoring, and 

socioeconomic issues. In the Atlantic, much of the recent focus of the ESP has been on establishing 

environmental baseline data and on visual impacts, space-use conflicts, and associated economic effects 

of renewable energy projects, but some research, especially that conducted historically, has focused on 

the impacts of oil and gas projects in the region. 

BSEE also has an active safety and technology research program. For example, the long-standing Oil 

Spill Response Research Program researches oil spill response technologies for oil spill detection, 

containment, treatment, recovery, and cleanup. Part of this research is conducted at the National Oil Spill 

Response Research Test Facility, Ohmsett, which allows testing of oil spill response technologies. BSEE 

conducts extensive oil spill response research on Arctic conditions, which considers how sea ice, cold 

temperatures, and hazardous conditions could potentially interfere with oil spill response in the Arctic. In 

addition, BSEE also manages a Technology Assessment Program that conducts research related to 

operational safety and pollution prevention. This program focuses on assessing offshore engineering 

technology to promote safety and environmental protection. 

In addition, BOEM receives information from other Federal agencies. In particular, BOEM collaborates 

with agencies such as NOAA and the U.S. Fish and Wildlife Service. Focusing on Alaska, the USGS 

published a report in 2011 outlining the additional information needs for Alaska oil and gas development 

(USGS 2011), and E.O. 13580 created the Interagency Working Group on Coordination of Domestic 

Energy Development and Permitting in Alaska to define information needs. Both documents have led to 

interagency coordination on research projects and information sharing in the U.S. Arctic. 

Further, BOEM works with non-Federal entities, such as Alaska Native groups, the scientific community, 

industry, tribal entities, and state and local governments. Valuable information has been obtained through 

collaboration and coordination with other entities, such as the North Pacific Research Board and the 

Arctic Research Council, which are involved in directing, conducting, and prioritizing science in the 

Arctic. One specific example includes the close coordination between BOEM and the Interagency Arctic 

Research Policy Committee to help develop the Arctic Research Plan for FY 2017–2021. BOEM also 

recently developed a partnership with the National Academies of Sciences, Engineering, and Medicine to 

provide independent information on environmental studies and assessment activities. The committee 

includes members with a broad range of expertise in the natural and social sciences, including ecology, 

sea ice, economics, noise, the application of science to policy, and other topics. 

BOEM has the ability to include new information at all stages of development of the National OCS 

Program and lease sale planning processes through its own research and that of other Federal agencies 

and nonFederal entities. BOEM also considers comments received from the public during each of the 

public comment periods. In developing a National OCS Program, BOEM acknowledges the everexpanding availability of scientific information. The development of the 2019–2024 Program includes, 

and will continue to include, new scientific information and stakeholder feedback to proactively identify 

and try to resolve potential conflicts. The Draft Programmatic EIS will be published in conjunction with 

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the Proposed Program decision document, which is the next stage in the National OCS Program 

development process. The Draft Programmatic EIS will provide a comprehensive analysis of the 

environmental information for the areas under consideration in the DPP decision. 

While the majority of the research discussed above is driven by the possibility of oil and gas operations 

and conducted to inform decision makers, the knowledge gained is largely “independent” learning. This 

follows Fisher and Hanemann’s (1987) suggestion that needed information about environmental impacts 

can sometimes be obtained by research separate from drilling. To that extent, there could be option value 

in waiting to drill while the research is being conducted. It is conceivable that the wait for information 

could extend beyond the five-year timeframe of a given National OCS Program, and the pyramidal 

structure of the National OCS Program development process allows for more refined research and 

analysis at the specific lease sale stage. Because the process from the National OCS Program 

development to the lease sale stage contains multiple steps, BOEM has several opportunities to 

incorporate new information and revise decisions. In particular, before a lease sale is held, a NEPA 

review is conducted and, if warranted, additional environmental and social costs are studied, in part based 

on new information. Furthermore, after the lease sale, additional environmental information is compiled 

and analyzed throughout the plan and permit approval processes. 

BOEM continues to investigate social and environmental issues and to consider the relevant factual 

information that is currently available. In the meantime, BOEM provides qualitative information to the 

Secretary to consider the existing uncertainties and how new information could become available for 

consideration in the decisions on size, timing, and location. Detailed information on the environmental 

impacts of each program area will be provided in the Draft Programmatic EIS, which will be published 

concurrently with the Proposed Program. 

Environmental and social costs are an important component in the net social value calculation. As such, 

the ranking of the planning areas could change with new information on the costs of OCS activity. 

However, an important aspect of OCS energy development is that in the absence of lease sales in any of 

the OCS planning areas, substitute sources of energy would be necessary to fulfill U.S. demand for 

energy. These substitute energy sources have their own environmental and social costs, which are also 

uncertain. Although BOEM does not do a detailed accounting of these substitute energy sources at this 

DPP stage, such sources are still an important consideration in the leasing decision. More information on 

the environmental and social costs of these energy substitutes will be discussed in future stages of the 

National OCS Program development. Information compiled for the 2017–2022 Program is included in 

Forecasting Environmental and Social Externalities Associated with Outer Continental Shelf (OCS) Oil 

and Gas Development – Volume 2 (Industrial Economics, Inc. and SC&A, Inc. 2015). 

Although the hurdle price analysis calculated in Section 10.1.2, Hurdle Prices, does not incorporate in a 

quantitative manner the range of the uncertainty of environmental and social costs or the possibility of 

irreversible damage, it does incorporate estimates of anticipated environmental and social costs into the 

hurdle price calculation. As was done in the 2017–2022 Proposed Program and PFP analysis, the hurdle 

price calculation considers both the private and social costs of exploration and development in 

determining the hurdle price. 

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10.1.1.6 Regulatory and Legal Environment Uncertainty 

An objective of both the government and industry is to manage the risks associated with OCS oil and gas 

operations. Operators manage these risks through use of industry best practices and prudent risk 

management. The government uses legal liability, and the promulgation and enforcement of safety and 

environmental laws and regulations. 

The ability to maintain a stable and transparent regulatory and legal environment for oil and gas industry 

operations is an important factor considered by lessees and operators on the OCS in choosing whether, 

when, and how much to invest in OCS tracts and related drilling and development activities. This fact 

was recognized in E.O. 13783 (Promoting Energy Independence and Economic Growth) and Secretarial 

Order 3349, which prompted a review of existing regulations and policies that potentially burden the 

development of domestic energy production. The legal and regulatory environment for OCS exploration 

and development can greatly impact project profitability. As the National OCS Program evolves, new 

regulations may be promulgated and existing regulations revised. Occasionally, implementation of new 

statutory requirements and legal precedents are inevitable in the interest of ensuring safe and 

environmentally sound OCS operations. The goal of BOEM and BSEE is to communicate and coordinate 

with the industry and other stakeholders on the content and rationale of regulatory approaches and 

requirements. The bureaus encourage feedback, input, and suggestions for alternatives to the regulatory 

proposals before they are finalized. 

Future legal and regulatory changes separate from the National OCS Program have the potential to affect 

OCS leasing and development, such as climate-related policies. Policy changes can also affect markets in 

ways that affect companies’ decisions about leasing, exploration, and production on the OCS. The 

pyramidal nature of the National OCS Program creates future decision points throughout the National 

OCS Program development and lease sale processes where, if necessary, changes could be made in 

response to new energy or climate policies. 

10.1.1.7 Price Uncertainty 

While the value promised by a lease sale is related to the resource endowment and the likelihood of 

finding economic hydrocarbon deposits, it also is heavily influenced by forecasts of future oil and natural 

gas prices. Mean reversion is one of several possible models that could be used to simulate oil and gas 

prices. The simplest model, used by Black and Scholes for valuing financial options, assumes geometric 

Brownian motion, which has the volatility of a mean-reversion model without the tendency to revert to a 

single long-run mean. In addition to the economic logic that implies that oil and gas prices tend to revert 

to a long-run cost, statistical tests can be applied to determine whether the oil or gas price series has a 

mean-reverting tendency. In one paper, Pindyck (2001) concluded that “over the long run, price behavior 

seems consistent with a model of slow mean reversion.” Under a mean-reversion framework, uncertainty 

stabilizes over time as prices revert back to a long-run mean. As such, under the meanreversion 

assumption there is little benefit to waiting because the uncertainty band narrows around the long-run 

average. However, should prices progress below the long-term trend, there could be benefit in waiting for 

prices to rebound 

To consider the option value of the resources related to resource price uncertainty and optimal timing 

decisions, BOEM has adopted a hurdle price analysis. It is intended to show that every area included in 

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the National OCS Program is expected to offer rights to at least one geologic field where prompt 

exploration during the 2019–2024 Program is consistent with an optimal intertemporal allocation of 

resources. The hurdle prices are calculated assuming a mean-reverting price model. At the DPP stage, 

the hurdle prices are calculated for each planning area fully evaluated in Section 5.3. These hurdle prices 

will be reviewed at the later stages in the National OCS Program development process and revised if 

necessary. The hurdle price analysis is again reviewed and reconsidered during the lease sale planning 

process. 

10.1.2 Hurdle Prices 

At the National OCS Program stage, to formally assess whether planning areas should be included in the 

National OCS Program given price uncertainty, BOEM subjected the assessment of undiscovered fields 

in each planning area to an appropriate economic analysis to determine an area “hurdle” weighted average 

(i.e., BOE) price. BOEM’s hurdle price analysis only considers the uncertainty surrounding oil price. 

While many other uncertainties exist (described in Section 10.1.1), given data availability and a lack of a 

widespread documented methodology for quantitatively evaluating other types of uncertainty, only price 

uncertainty is evaluated quantitatively at this time. The hurdle price is defined as the market price below 

which the social value of delaying to a future program exploration of a large field in the sale area would 

exceed the value of immediate exploration of those fields within this program.45 That is, when market 

prices are at or above the hurdle price, the value of allowing exploration for these large prospects exceeds 

the value of delay. Greater social value could be realized by leasing that prospect now than delaying for 

future leasing. Note that other timing, composition, and sale design decisions are relevant to, and 

considered at, the lease sale stage. Whether full value may be realized from leasing other prospects as 

well will be determined in future analyses. This approach has the advantage of identifying areas at the 

DPP stage which show current economic promise of at least one geologic field, while deferring other 

timing, composition and sale design decisions to later in the National OCS Program process or to the 

lease sale stage. 

Once the National OCS Program is approved, the lease sale design stage re-visits the decision of whether 

to hold a sale that is included in the National OCS Program and evaluates which OCS blocks to offer and 

how to set the sale terms. Designing specific lease fiscal terms at the lease sale stage rather than the 

earlier National OCS Program formulation stage provides more flexibility (i.e., option value) and allows 

decisions to be made closer to the time when economic and other conditions that influence sale decisions 

are better known and somewhat easier to forecast. Given the iterative process of National OCS Program 

development and lease sale design, there are benefits from including areas in the National OCS Program 

if their hurdle prices are below current prices as further analysis can be conducted at a later stage 

(i.e., individual lease sale stage). Section 10.3.2, Fiscal and Lease Terms, provides more discussion on 

BOEM’s lease sale fiscal terms procedures. 

The hurdle price analysis is conducted considering the NSV of each planning area and determines 

whether the value from leasing in the current National OCS Program is expected to be greater than 

waiting to lease an area until a future National OCS Program. For this calculation, BOEM considers both 

45 All else being equal, the largest fields tend to have the highest net value per equivalent barrel of resources, so they are least 

likely to benefit from delaying leasing in anticipation of increasing resource prices. BOEM used the 95th percentile field size as 

the approximate largest field size available in each program area. 

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the private and social costs of exploration and development. For the DPP analysis, BOEM calculated the 

hurdle prices for each of the 15 planning areas with more than 100 million BOE. As discussed in 

Section 5.2.6, the other 11 planning areas were determined to have negligible resources and/or 

development potential, and therefore, are unlikely to have production at any price. 

Within each planning area, BOEM selected for use in the hurdle price analysis an approximation of a 

large undiscovered field size, which was identified by our statistical resource estimation model. As 

described in Appendix B, for this DPP, BOEM used the 95th percentile field size from the 2016 National 

Assessment to define the large field size available in each planning area (BOEM 2016a). This field size 

was then used for conducting the hurdle price analysis in each planning area in conjunction with private 

and social cost estimates appropriate for the applicable water depths and field sizes. These factors were 

input into an in-house dynamic programming model to generate the hurdle prices. The rationale for 

basing the hurdle price analysis on large fields relates to the likelihood that larger fields are more valuable 

to develop, even after including social costs, than smaller fields. It is possible, for certain price 

assumptions, that social benefits would be optimized by leasing large fields in the 2019–2024 Program 

while holding small fields for later leasing. Since the locations of undiscovered fields are unknown, 

however, a single timing decision must be made for areas in their entirety. If the area is included in the 

National OCS Program and leasing conducted due to the possibility of large fields, a social cost of 

prematurely leasing some small fields might be incurred. 

Table 10-1 shows the NSV for each of the planning areas/locations that were analyzed. Column B in 

Table 10-1 shows the input field sizes for each area. Columns C and D show the assumptions made about 

natural gas-oil ratios for each area along with the relative proportion of oil and natural gas associated with 

each area as implied by that ratio. For example, in the Cook Inlet there are 1.19 mcf of natural gas for 

every barrel of oil. This, on a BOE basis,46 means that on average, approximately 83 percent of a field is 

oil, and 17 percent is natural gas. BOEM uses the model When Exploration Begins, version 3 (WEB3) to 

estimate the BOE hurdle prices shown in Column E of Table 10-1. At all prices below the hurdle price, 

delaying exploration of an undiscovered field of the size shown in Column B is more valuable than 

immediate exploration. The hurdle prices are per BOE and shown in 2019 dollars. More details on the 

calculation of applicable oil and natural gas prices that derive from the BOE hurdle prices are included in 

Appendix B. 

To compare the calculated BOE hurdle prices with expectations of future prices during the 

2019–2024 Program, BOEM compared the BOE hurdle prices with forecasts from the EIA’s AEO 

(EIA 2016). The EIA’s 2017 AEO forecasts the oil price in 2019 (in 2019 dollars) will be $74.85 per 

barrel and the gas price will be $4.22 per million Btus (or $4.38 per mcf). These prices are then 

converted to a BOE price in each of the planning areas, as shown in column F. The forecasted oil and gas 

prices are consistent across all planning areas, but each relates to a unique BOE price given the specific 

natural gas-oil ratio in each area. The BOE prices in each area represent the expected 2019 value of the 

resources in that planning area given the average composition of oil and natural gas. The BOE prices 

from column F are to be compared with the BOE hurdle prices shown in column E. 

46 On a thermal basis, 5.62 mcf of natural gas provides the same heat content as a barrel of oil. 

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Table 10-1: NSV Hurdle Prices 

A B C D E F 

Planning Area or 

Location 

Large 

Undiscovered 

Field 

Natural 

Gas-Oil 

Ratio 

Portion of Field 

BOE 

NSV 

Hurdle 

Price 

AEO BOE 

2019 Price 

(million BOE) Oil Natural 

Gas 

Price per 

BOE 

Price per 

BOE 

Beaufort Sea 357 3.36 63% 37% $44.00 $56.02 

Chukchi Sea 706 4.99 53% 47% $40.00 $51.19 

North Aleutian Basin 230 11.49 33% 67% $37.00 $41.07 

Cook Inlet 175 1.19 83% 17% $22.00 $66.07 

Gulf of Alaska 169 6.41 47% 53% $32.00 $48.04 

Washington/Oregon 11 5.70 50% 50% $43.00 $49.52 

Northern California 45 1.72 77% 23% $57.00 $63.05 

Central California 44 1.04 84% 16% $69.00 $67.01 

Southern California 86 1.46 79% 21% $43.00 $64.48 

Western GOM 179 1.29 81% 19% $30.00 $65.46 

Central GOM 178 1.70 77% 23% $28.00 $63.17 

Eastern GOM 178 2.20 72% 28% $27.00 $60.70 

South Atlantic 46 4.34 56% 44% $47.00 $52.93 

Mid-Atlantic 362 10.22 35% 65% $27.00 $42.39 

North Atlantic 182 6.64 46% 54% $36.00 $47.60 

Note: The large undiscovered field size is defined as the 95th percentile field from the 2016 National Assessment field size distribution. The 

95th percentile represents very large field sizes while avoiding outlier values. See Appendix B for further elaboration. The estimate of large 

field sizes in the GOM planning areas are based on the assumption that the largest field will be in deepwater and modeled accordingly. 

With one exception, the weighted BOE forecast prices for 2019 exceed the hurdle price in all of the 

planning areas. For those areas, the analysis does not point to the need to delay leasing in any of these 

areas for option value considerations. However, as shown in Table 10-1, the hurdle price calculated for 

the Central California Planning Area indicates that waiting in the region could provide greater value to 

society than leasing in the 2019–2024 Program. This planning area has higher relative environmental and 

social costs given higher ecological and air quality costs compared to the other California planning areas, 

which lead to a higher hurdle price. BOEM notes that the calculation of hurdle prices is highly dependent 

on several assumptions, especially those about the future price trend of oil and natural gas and on the rate 

at which prices revert to that trend. More detail on these assumptions and the sensitivities of the hurdle 

prices are included in the Economic Analysis Methodology paper (BOEM 2016b). Further, the hurdle 

price analysis only considers the uncertainty associated with resource prices. Accordingly, the hurdle 

price findings should be taken as a guide only for price-based option value. 

The lease sale stage provides another opportunity to revisit the hurdle price analysis and consider whether 

to hold a lease sale. As discussed, option value is merely one component of BOEM’s FMV analyses and 

Program formulation. Additional and more robust analysis could be conducted at later stages. This is 

especially important as new information becomes available that could affect the resource estimates or 

private or social costs for any of the planning areas. To capture the option value of new information 

becoming available that could make an area more or less profitable to lease, the Secretary may choose to 

include or exclude areas regardless of the relationship between the hurdle prices and current prices. 

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In addition to the other considerations discussed in this chapter and throughout this document, another 

factor for the Secretary to take into account is the value of a predictable lease sale schedule. There is 

value in the stability of planned lease sales. The creation of a National OCS Program lease sale schedule 

allows companies the opportunity to plan expenditures and future prospects. Choosing to cancel sales 

based purely on the hurdle price is not costless and could possibly have an adverse impact on company 

interest in the region and the value received by the public. As such, the Secretary considers many other 

factors in the decision of whether to include an area in the program and ultimately hold a sale. 

10.2 LEASING FRAMEWORK 

The size of a lease sale and the frequency of sales within a planning area are other FMV considerations 

within the National OCS Program framework. 

10.2.1 Size of a Lease Sale 

With regard to the size of a lease sale, BOEM considers whether all acreage within a planning area should 

be included in the sale, or whether a more focused area should be made available for leasing. Since 1983, 

GOM lease sales have been conducted under the area-wide leasing format. Area-wide leasing means that 

all available (unleased and not restricted) acreage in the planning area is offered in the sale auction. Prior 

to 1983, BOEM used an industry nomination/agency tract selection process in which companies 

nominated acreage or BOEM selected specific acreage for lease, and only that acreage was offered. The 

tract selection lease sales would tend to sell fewer leases and allow more focused environmental analyses. 

The State of Louisiana requested on several occasions the use of schemes other than area-wide leasing, 

similar to industry nomination/agency tract selection. In 2010, BOEM contracted a study analyzing areawide leasing. The study, Policies to Affect the Pace of Leasing and Revenues in the Gulf of Mexico, 

evaluated the efficacy of alternative leasing schemes to the area-wide leasing model (BOEMRE 2011; 

hereinafter referred to as “Area-wide Leasing Study”). 

The Area-wide Leasing Study suggests that government revenues in the form of increased cash bonus 

bids per block leased under the nomination/tract selection format would be offset by fewer blocks leased, 

less drilling, a reduced pace of discovery, lower rentals and royalties, and less annual future production of 

OCS oil and natural gas from newly issued leases. Further, in the process of considering alternative 

leasing approaches and fiscal systems that could enhance government revenue and assure receipt of FMV, 

BOEM must be cognizant of the effects any policy changes might have on the achievement of other 

statutory goals of the National OCS Program. Among these are expeditious and orderly development and 

maintaining a diverse and competitive industry. By allowing a range of blocks to be included in a sale, 

area-wide leasing allows smaller companies to expeditiously acquire, explore, and produce low-resource, 

low-risk fields, while providing larger companies with an incentive to pursue technological development 

in deep water. Area-wide leasing also encourages innovative exploration strategies and is consistent with 

maintaining financially sound geophysical contracting and processing industries. In addition, the bidding 

system, minimum bid, and fiscal terms for a given lease sale influence the number and value of leases 

sold in the sale. 

In development or implementation of the National OCS Program, BOEM can design the size and scope of 

a program area or lease sale area, respectively, and adopt a more focused approach in particular areas. 

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These decisions are more often implemented at later National OCS Program development stages or during 

the lease sale stage. More focused leasing is geographically targeted in scope and could be used in any 

OCS region to achieve an appropriate balance between making resources available and limiting conflicts 

with states’ CZM Plans, environmentally sensitive areas, and subsistence use by making certain 

determinations from the outset about which blocks within the planning area are most suitable for leasing. 

In the remaining National OCS Program development steps and in the sale design for specific lease sales, 

BOEM will continue to analyze the use of area-wide leasing and focused leasing. BOEM will consider 

both FMV and other concerns, such as environmental and subsistence issues, when determining whether 

to hold area-wide or more focused lease sales in a particular area. 

10.2.2 Frequency of Lease Sales 

Another consideration at the National OCS Program stage is the frequency of lease sales within the years 

covered by a particular National OCS Program. When deciding the frequency of lease sales to be held in 

a particular area, an important consideration is the potential for new information (e.g., geologic 

information, revised price forecasts, new technology) to become available between sales. In the GOM 

Region, seismic activity, exploration well drilling, and lease relinquishments are occurring almost 

continuously. Thus, in the GOM Region, the emerging information and tract availability could impact a 

company’s bidding strategy as well as the government’s evaluation of blocks. Accordingly, and partly in 

response to demand and the new information, an efficient GOM lease sale schedule tends to involve more 

frequent sales. In other areas where little or no current activity exists and there would be minimal to no 

new information between sales, it could be more appropriate to have a lease sale schedule with less 

frequent sales. Of course, other factors (such as changing prices) may warrant more or fewer sales in a 

particular area throughout the National OCS Program. 

Additional information on the frequency of lease sales will be considered throughout the development of 

the National OCS Program. 

10.3 OTHER COMPONENTS OF FMV 

After an area is included in an approved National OCS Program, and following the determination of the 

lease sale size and timing, the next decision is the selection of the bidding system and lease terms to be 

used for the lease sale offering. These terms are evaluated prior to each lease sale to ensure the terms 

provide the public with FMV for the rights conveyed. After the lease sale and before acceptance, each 

bid is evaluated for bid adequacy. The lease sale components for ensuring receipt of FMV consist of 

bidding system, lease terms, and bid adequacy review together. 

10.3.1 Bidding Systems 

In designing a lease sale, BOEM determines the appropriate bidding system. The specific competitive 

bidding systems available under the OCS Lands Act are codified in 30 CFR § 560.202. The OCS Lands 

Act requires the use of a sealed bid auction format with a single bid variable on tracts no larger than 

5,760 acres, “unless the Secretary finds that a larger area is necessary to comprise a reasonable economic 

production unit” (43 U.S.C. § 1337(b)(1)). The OCS Lands Act allows for different competitive bidding 

variables including royalty rates, bonus bids, work commitments, or profit sharing rates. 

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When Congress amended the OCS Lands Act in 1978, it instructed USDOI to experiment with alternative 

bidding systems for OCS leasing, primarily to encourage participation of small companies by reducing 

upfront costs associated with the traditional cash-bonus bid system. USDOI used four alternative bidding 

systems from 1978 through 1982. Almost all of the tested systems maintained the cash bonus bid, but 

varied the contingency variable with use of a sliding scale royalty, which varied depending on the rate of 

production; a fixed net profit share; and 12.5 and 33 percent royalty rates. These systems were not found 

to enhance National OCS Program performance compared to the then-prevalent 16.67 percent fixed 

royalty rate system in shallow water. Among other things, they did not increase participation by small 

companies; were significantly more complex to administer; distorted bids, which made it more difficult to 

identify the high bid; and often were not beneficial to the taxpayer. As a result, since 1983, BOEM has 

chosen to use the cash-bonus bidding system subject primarily to a mid-range fixed royalty rate. 

In evaluating which competitive bidding terms to use, BOEM considers the goals of the OCS Lands Act, 

the costs and complications of implementing the selected approach, the ability of the bidding variables to 

accurately identify the bidder offering the highest value, and the economic efficiency of the selected 

approach. 

In preparation for specific lease sales, BOEM analyzes alternative fiscal terms to offer in conjunction with 

the current bidding systems as well as considers alternative bidding systems as appropriate. These are 

described in Section 10.3.2, Fiscal and Lease Terms. 

10.3.2 Fiscal and Lease Terms 

After deciding to hold a lease sale and the bidding system to be used, the next set of decisions deals with 

the sale terms to be offered, largely the fiscal terms and duration of the primary term. The fiscal terms 

include an upfront cash bonus, rental payments, and royalties, with the rental and royalty terms set by 

BOEM and the upfront cash bonus offered by bidders subject to BOEM’s minimum bid level. All of the 

financial obligations (cash bonus, rental payments, and royalties) reflect the value of the lessor’s 

(i.e., Federal Government’s) property interest in the leased minerals and are fiscal components of FMV. 

In determining the appropriate lease terms for a sale, BOEM must balance the need to receive FMV with 

the policy goals in the OCS Lands Act, such as expeditious and orderly development of OCS resources. 

BOEM evaluates fiscal and lease terms on a sale-by-sale basis and has adjusted these in recent lease sales 

in response to emerging market and resource conditions, competition, and the prospective nature of 

available OCS acreage. 

BOEM follows formalized procedures for evaluating fiscal terms before lease sales. These annual 

procedures consider the effectiveness of the status quo fiscal terms in comparison to international fiscal 

systems and recent National OCS Program performance. During these procedures, BOEM updates it’s 

inhouse analytical models, conducts additional statistical analysis, reviews international fiscal system 

trends, and recommends either adopting fiscal terms that have been used in previous lease sales or other 

alternative fiscal terms. BOEM’s procedures include use of both discounted cash flow and real option 

methods for deciding the set of fiscal terms that maximize the potential value of future leasing and 

production while ensuring receipt of FMV. 

BOEM’s procedures are informed by two recent studies that consider both international fiscal systems 

and alternative fiscal terms. BOEM, jointly with the Bureau of Land Management, completed a study 

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with IHS-Cambridge Energy Research Associates entitled Comparative Assessment of the Federal Oil 

and Gas Fiscal Systems (BOEM and BLM 2011). The study compared other countries’ petroleum 

extraction fiscal systems and terms to the U.S. Federal system and found that, from a government 

perspective, the current GOM lease fiscal terms rank favorably with the fiscal terms employed by other 

countries that compete with the United States for upstream oil and gas investment. As discussed 

previously, BOEM also conducted the 2010 Area-wide Leasing Study to consider a range of alternative 

fiscal terms. The study was not able to identify alternative leasing and fiscal policies that would lead to 

significant increases in Federal revenues. 

After lease sales are held, the bidding on blocks is analyzed to determine whether the lease terms offered 

have enhanced bidding and competition for leases and to evaluate the necessity for additional changes or 

adjustments. Lease terms are set sale-by-sale and are annually evaluated to determine whether market 

conditions warrant a change. In general, any changes in fiscal terms are done incrementally allowing 

BOEM the opportunity to evaluate the results of a lease sale held with new sale terms and to further refine 

terms if necessary in future lease sales without incurring undue risk to the National OCS Program. Each 

of the lease sale terms contributes to the assurance of FMV for the public’s resources. BOEM reevaluates minimum bid levels and rental and royalty rates on a sale-by-sale basis and can establish 

alternative rates in the event that changing conditions no longer assure FMV or are inhibiting expeditious 

and orderly development of OCS acreage. 

10.3.2.1 Minimum Bid and Bonus Bid Amounts 

For many years, the bid variable of the auction has been the bonus bid. This signature bonus is a cash 

payment required at the time of lease execution. A bonus bid is formulated by the bidder based on its 

perception of expected profit, net of other payments. A minimum bid is set as a floor value for acquiring 

the rights to OCS acreage. Historically, its primary utility has been to ensure receipt of FMV on blocks 

for which there are insufficient data to make a tract evaluation, or existing geologic or economic potential 

of the blocks is inadequate to support a positive tract value. BOEM increased the minimum bid in the 

deepwater GOM in 2011 to encourage optimal timing of leasing and drilling for low-valued blocks in 

deep water. 

The bonus bid is paid at the outset regardless of future activity or production, if any, so the lessee bears 

the risk of paying more than the lease is eventually worth, while the government bears the risk of 

accepting less than it is eventually worth. In contrast, the royalty has neither risk because it is based on 

actual production. A fiscal advantage of the bonus is that it is received by the government immediately; 

there is no delay of, possibly, a decade or more as with the royalty. 

A higher minimum bid results in a greater proportion of offered blocks being passed over (i.e., not bid on) 

by bidders. To the extent these passed-over blocks are marginally valued, their retention in the 

government’s inventory and reoffering at the next lease sale could enhance the efficiency of the lease sale 

process and generate option value and higher bonus bids for the retained blocks. A higher minimum bid 

level can also serve to narrow bidder interest to the more valuable blocks offered in the lease sale, thereby 

enhancing competition on the better blocks and encouraging bidders to focus their bidding on those 

blocks that they are most likely to explore and develop. As discussed in Section 10.1, Timing of OCS 

Lease Sales and Related Activities, the minimum bid can be adjusted to improve timing of activities 

where option value is found to be significant. While higher minimum bid levels can have a significant 

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effect on decreasing the number of blocks leased, aggregate cash bonuses could be little affected or could 

even increase, since raising the minimum bid level can push bids to higher levels. 

Although the minimum bid stipulates the lowest bid level, actual bids submitted are based on the expected 

profitability of the field and evaluated based on geology and economic viability (as described in 

Section 10.3.2.5, Bid Adequacy). Bidders develop the actual amount of their bonus bid in consideration 

of the expected profit, net of other payments. Accordingly, the fiscal terms in effect in a lease sale can 

affect the amount of the bonus bid of a lease and changes in other fiscal terms can affect the revenues 

collected through bonuses. For example, a higher expected royalty or rental rate induces bidders to 

formulate lower bonus bids, and vice versa. Rentals and royalties are discussed in Sections 10.3.2.2, 

Rentals, and 10.3.2.3, Royalties. 

10.3.2.2 Rentals 

Before commencement of royalty-bearing production, the lessee pays annual rentals that are generally 

either fixed or escalating. Rentals compensate the public for the value of holding the lease during the 

primary term and encourage diligent development. BOEM has used escalating rentals for leases in the 

Chukchi and Beaufort Seas in Alaska and the GOM to encourage timely exploration and development or 

earlier relinquishment. The primary use of escalating rentals is to encourage swift exploration and 

development of leases, and earlier relinquishment when exploration is unlikely to be undertaken by the 

current lessee. Escalating rentals have also been used when the initial lease period is extended following 

the spudding of a well, which in some cases in the GOM must be targeted to a drill depth of at least 

25,000 feet subsea. 

Rental payments serve to discourage lessees from purchasing marginally valued tracts too soon since 

companies are hesitant to pay the annual holding cost to keep a low-valued or currently uneconomic 

leases in their inventory. Rental payments provide an incentive for the lessee to either drill the lease in a 

timely manner or relinquish it before the end of the initial lease period, thereby giving other market 

participants an opportunity to acquire these blocks in a more timely fashion. 

10.3.2.3 Royalties 

The government reserves a royalty interest for all OCS production. Leases issued in recent years have a 

fixed royalty rate; by law, it must be no lower than 12.5 percent. The rate is applied to the value of oil 

and gas sold, net of certain transportation and processing costs. The amount collected per barrel is greater 

or lesser as the oil price changes, but the rate itself does not vary. It is also the lease fiscal term in which 

the government shares in the risk of the lease (i.e., the government only receives royalty revenues if 

production has commenced). In bidding systems that include a royalty component, the minimum royalty 

rate allowed by law is 12.5 percent. Alternative royalty arrangements are possible in which the rate varies 

above that level or no royalty is paid for certain periods. 

Royalty rates can have a significant impact on bidder interest and are a key fiscal parameter in the 

calculation of the underlying economic value for a block. BOEM increased the GOM royalty rate in lease 

sales held in 2007 and 2008 to capture a greater portion of revenue because oil and gas prices had risen 

substantially above levels that prevailed for virtually all previous years. BOEM recently issued leases in 

GOM Regionwide Lease Sale 249 in water depths less than 200 meters with a royalty rate of 12.5 percent. 

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The decision to offer shallow water leases with a 12.5 percent royalty rate came at the conclusion of the 

annual lease term reassessment process and was the result of analysis of market conditions; international 

considerations; available resources; leasing, drilling, and production trends; and other factors. 

In designing specific lease sales, BOEM undertakes additional royalty rate analysis. BOEM is currently 

studying an alternative to the fixed royalty rate, a price-based royalty. Such a system would provide an 

incentive to lessees through lower royalty rates in times of lower oil prices, while also ensuring that the 

Federal Government receives a greater return for OCS resources when prices are high. BOEM is 

exploring the possibility of a price-based royalty and will continue to evaluate the concept. 

10.3.2.4 Primary Term 

In cases where a high bid meets the FMV requirements, the lease rights are issued to the lessee for a 

limited term called the primary term. The OCS Lands Act sets the primary term at 5 years, or up to 

10 years, “where the Secretary finds that such longer period is necessary to encourage exploration and 

development in areas because of unusually deep water or other unusually adverse conditions....” The 

primary term promotes expeditious exploration while still providing sufficient time to commence 

development. In evaluating the primary term of the lease, BOEM considers technology and the time 

necessary for exploration and infrastructure development. When designing specific lease sales, BOEM 

considers the length of the primary term and whether it remains appropriate given current exploration 

timeframes. For example, in 2010, BOEM reduced the primary term for leases in water depths of 800 to 

1,600 meters to reflect the shorter time deemed necessary to explore for economic prospects. 

10.3.2.5 Bid Adequacy 

Following a lease sale, the high bids on each block are evaluated to determine whether they satisfy the 

FMV requirements for acceptance. The bid adequacy process, instituted in 1983, uses a twophased 

system to assess the adequacy of bids received in lease sales. The first phase involves BOEM’s 

assessment of the block’s geologic and economic viability. The high bids that are not accepted during 

this first phase are evaluated in the second phase using detailed analytical assessment procedures to 

generate an independent evaluation of each remaining block’s value. This procedure is employed in 

conjunction with the distribution of the losing bids on each block and with an adjustment for the delay 

cost, if any, from not selling the block in the current lease sale to determine each block’s ultimate 

“reservation price.” This price cannot be lower than the minimum bid set for the auction, but it could be 

higher for particular blocks. If the high bid does not exceed the reservation price, the bid is rejected and 

the block is available to be reoffered at the next lease sale in that area. Thus, BOEM reviews all high bids 

received and evaluates all blocks using some combination of block-specific bidding factors and detailed 

blockspecific resource and economic evaluation factors to ensure that FMV is received for each lease 

issued. 

Since 1984, bid adequacy reviews and FMV determinations have resulted in an average rejection rate of 

bids of approximately 3.7 percent. One effect of bid rejection is to encourage bidders to submit bids that 

will exceed the government’s reservation price and thereby promote receipt of FMV. Moreover, rejection 

of high bids under the existing BOEM bid adequacy procedures has consistently resulted in higher 

average returns in subsequent lease sales for the same tracts, even when those tracts not receiving 

subsequent bids were included in the calculation of the average returns. In the GOM from 1984 through 

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2017, BOEM rejected total high bids of $638 million, but when the blocks were reoffered, they drew 

subsequent high bids of $1.8 billion, for a total net gain of $1.2 billion, or an increase of 187 percent. 

These results indicate that BOEM’s bid adequacy assessments and procedures have performed well in 

identifying blocks with high bids below FMV. With the possibility of bid rejection from the government 

and competition from other bidders, lease sale participants are encouraged to submit bids that will tend to 

reflect or exceed the government’s reservation price. When bids exceed the reservation price, the 

government is confident it is receiving FMV. 

BOEM occasionally conducts look-back studies to evaluate bid evaluations and actual development. 

These studies show that the majority of OCS leases with profitable hydrocarbon discoveries were 

assigned a positive value at the time of sale. However, in some cases where block values were estimated 

to be negative and the blocks were issued for near-minimum bid, the lessees made discoveries of 

substantial size. In these cases, BOEM has documented that either new information became available 

after the lease was awarded, prompting a company to drill a specific target different than what was 

originally evaluated, or the BOEM evaluation of the potential oil and gas accumulation target did not 

coincide with that of the lessee company. In those cases where new information became available after 

the lease was awarded, the information tends to be either new or reprocessed geophysical data unavailable 

at the time of sale, or new subsurface well data acquired as a result of drilling on a nearby lease that could 

indicate the possibility of material hydrocarbon deposits on the subject lease. Since it is quite common 

for exploration companies to acquire new or reprocessed geophysical data on leases after award but prior 

to exploratory drilling, these look-back studies tend to identify those wells that have been drilled to a 

target that sometimes are not coincident with the target that was evaluated pre-sale. 

Bid adequacy procedures are dynamic; as conditions change, BOEM looks for opportunities to improve 

the process. The original form of the bid adequacy procedures was instituted in 1983 in conjunction with 

the implementation of the area-wide leasing policy, but these procedures have undergone several 

refinements to address FMV concerns as conditions have changed. The current procedures are available 

online at http://www.boem.gov/Fair-Market-Value/. 

BOEM continues to look for opportunities to improve the process and is currently refining the tract 

evaluation model used in bid adequacy determinations. Moreover, in implementing a new National OCS 

Program, there could be revisions to the bid adequacy procedures to incorporate new knowledge or 

accommodate structural changes to the leasing process. 

10.4 CONCLUSION 

BOEM evaluates market conditions, available resources, bidding patterns, and the status of production on 

OCS acreage when establishing terms and conditions for each lease sale. While some components of 

FMV are initially discussed at the National OCS Program stage (i.e., optimal timing and leasing 

framework), other components (i.e., fiscal and lease terms, bidding systems, and bid adequacy) are 

considered on a salebysale basis to incorporate new information and assure FMV is received. At this 

DPP stage, the planning area hurdle price analysis, based on calculated BOE hurdle prices in comparison 

to current expectations of future prices for oil and gas, does not indicate that any of the planning areas, 

except for possibly one—the Central California Planning Area, should be excluded based solely on the 

price of oil and gas. Of course, this is only one consideration in the National OCS Program development 

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process, and the Secretary may remove areas based on other factors (e.g., environmental considerations, 

industry interest). In the event that BOEM changes any of the lease sale terms, bidding system, or bid 

adequacy procedures, the changes are announced to the public and industry through the Proposed NOS or 

other notification in the Federal Register, typically prior to publication of the Final NOS. 

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Chapter 11 Glossary 

2-D Seismic — A seismic survey where a line of geophones captures enough information to generate a 

two-dimensional (height and length) image of the Earth’s subsurface directly below the line. 

3-D Seismic — A seismic survey where a three-dimensional image of the subsurface is developed by 

combining numerous energy sources and multiple lines of geophones. The image consists of height, 

length, and side-to-side information that gives better resolution to the subsurface. 

Area Identification (Area ID) — The Area ID is an administrative pre-lease step that describes the 

geographical area of the proposed actions (proposed lease sale areas) and identifies the alternatives, 

mitigating measures, and issues to be analyzed in the corresponding NEPA document. 

area-wide leasing — All available (unleased and not withdrawn) acreage in the program area will be 

offered in the lease sale. 

barrel — The standard unit of measurement of liquids in the petroleum industry, which is 42 U.S. 

standard gallons. 

barrel of oil equivalent (BOE) — The amount of energy resource (in this document, natural gas) that is 

equal to one barrel of oil on an energy basis. The conversion is based on the assumption that one barrel of 

oil produces the same amount of energy when burned as 5,620 cubic feet of natural gas. 

basin — A depression in the earth’s surface where sediments are deposited, usually characterized by 

sediment accumulation over a long interval; a broad area of the earth beneath which layers of rock are 

inclined, usually from the sides toward the center. 

benthic — Ecological zone at the bottom of a body of water; in this document, the seafloor surface and 

subsurface. 

bid — An offer for an OCS lease submitted by a potential lessee in the form of a cash bonus dollar 

amount or other commitments responding to a variable fiscal term as specified in the final notice of sale. 

block — A numbered area on an OCS leasing map or official protraction diagram (OPD). Blocks are 

portions of OCS leasing maps and OPDs that are themselves portions of planning areas. Blocks vary in 

size, but are typically 5,000 to 5,760 acres (about 9 square miles or 2,304 hectares). Each block has a 

specific identifying number, area, and latitude and longitude coordinates that can be pinpointed on a 

leasing map or OPD. 

bonus bid — The cash consideration paid to the United States by the successful bidder for a mineral 

lease. The payment is made in addition to the rent and royalty obligations specified in the lease. 

Bureau of Ocean Energy Management — On October 1, 2011, the Bureau of Ocean Energy 

Management (BOEM) was created. BOEM is responsible for managing development of the Nation’s 

offshore resources in an environmentally and economically responsible way. Functions include: Leasing, 

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Plan Administration, Environmental Studies, National Environmental Policy Act (NEPA) Analysis, 

Resource Evaluation, Economic Analysis, and the Renewable Energy Program. 

Bureau of Safety and Environmental Enforcement — On October 1, 2011, the Bureau of Safety and 

Environmental Enforcement (BSEE) was created. BSEE is responsible for enforcing safety and 

environmental regulations. Functions include: all field operations including Permitting and Inspections; 

Research for Offshore Regulatory Programs; Oil Spill Response, and Training; and Environmental 

Compliance functions. 

categorical exclusion — A category of actions which do not individually or cumulatively have a 

significant effect on the human environment and which have been found to have no such effect in 

procedures adopted by a Federal agency in implementation of these regulations (§1507.3) and for which, 

therefore, neither an environmental assessment nor an environmental impact statement pursuant to NEPA 

is required (40 CFR 1508.4). 

categorical exclusion review — The process by which an agency determines whether an action falls 

within a categorical exclusion. 

catastrophic discharge event — A low-probability, unexpected, and unauthorized large discharge of oil 

into the environment that could cause long-term and widespread effects on marine and coastal 

environments. 

conceptual play — Geologic plays in which hydrocarbons have not been detected, but for which 

geological and geophysical data, integrated with regional geologic knowledge, suggest that hydrocarbon 

accumulations may exist. 

continental shelf — A broad, gently sloping, shallow feature extending from the shore to the continental 

slope. 

continental slope — A relatively steep, narrow feature paralleling the continental shelf, the region in 

which the steepest descent to the ocean bottom occurs. 

conventional reservoir — A hydrocarbon accumulation in which reservoir and fluid characteristics 

typically allow oil or natural gas to flow readily into a well. This distinguishes the resources from 

unconventional reservoirs where there is little to no significant force driving the migration of resources to 

a wellbore. 

conventional resources — Oil and gas resources in conventional reservoirs where buoyant forces keep 

resources in place beneath a caprock. 

conventional recovery methods — Producing oil and gas resources using traditional extraction methods, 

such as natural pressure, pumping, or by using secondary methods such as gas or water injection. 

critical habitat — A designated area that is essential to the conservation of an endangered or threatened 

species that may require special management considerations or protection. 

crude oil — Petroleum in its natural state as it emerges from a well, or after it passes through a gas-oil 

separator, but before refining or distillation. 

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Department of the Interior (Department, USDOI) — The Department of the Interior is a Cabinet-level 

agency that manages America’s vast natural and cultural resources. 

Determination of NEPA Adequacy — A Determination of NEPA Adequacy (DNA) memo is not a 

NEPA document, but is used by BOEM in the decision file to document review of existing NEPA 

documentation for applicability and adequacy to address a new proposed action. 

development — Activities following exploration, including the installation of facilities and the drilling 

and completion of wells for production purposes. 

development and production plan — A plan describing the specific work to be performed on an 

offshore lease after a successful discovery, including all development and production activities that the 

lessee proposes to undertake during the time period covered by the plan and all actions to be undertaken 

up to and including the commencement of sustained production. The plan also includes descriptions of 

facilities and operations to be used, well locations, current geological and geophysical information, 

environmental safeguards, safety standards and features, schedules, and other relevant information. All 

lease operators are required to formulate and obtain approval of such plans by BOEM before development 

and production activities may begin; requirements for submittal of the plan are identified in 

30 CFR 550.241. 

Draft Proposed Program (DPP) — Section 18 of the OCS Lands Act requires the Secretary of the 

Interior to prepare and maintain a schedule of proposed OCS oil and gas lease sales determined to “best 

meet national energy needs for the five-year period following its approval or reapproval.” The DPP is the 

first of three proposals to be issued before a new National OCS Program may be approved. Preparation 

and approval of a National OCS Program is based on a consideration of principles and factors specified 

by Section 18 to determine the size, timing, and location of lease sales. 

endangered species — Any species that is in danger of extinction throughout all or a significant portion 

of its range and has been officially listed by the appropriate Federal agency (either the National Oceanic 

and Atmospheric Administration [NOAA] or U.S. Fish and Wildlife Service) under the Endangered 

Species Act; a species is determined to be endangered (or threatened) because of any of the following 

factors: (1) the present or threatened destruction, modification, or curtailment of its habitat or range; 

(2) over utilization for commercial, sporting, scientific, or educational purposes; (3) disease or predation; 

(4) the inadequacy of existing regulatory mechanisms; or (5) other natural or man-made factors affecting 

its continued existence. 

environmental assessment — A concise public document prepared pursuant to NEPA and the Council 

on Environmental Quality regulations. In the document, a Federal agency proposing (or reviewing) an 

action provides evidence and analysis for determining whether it must prepare an environmental impact 

statement or whether it finds there is no significant impact (i.e., Finding of No Significant Impact). 

environmental impact statement (EIS) — A public document prepared pursuant to NEPA and Council 

on Environmental Quality regulations for a major Federal action significantly affecting the environment. 

EISs provide a full and fair discussion of significant environmental impacts to inform decision makers 

and the public of the reasonable alternatives which would avoid or minimize adverse impacts. The 

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USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

document is used by Federal officials, in conjunction with other relevant material, to plan actions and 

make decisions. 

environmental sensitivity — A measure of the vulnerability and resilience of a region’s ecological 

components to potential adverse impacts of offshore oil and gas exploration and development activities in 

the context of existing conditions. 

established play — Geologic plays in which hydrocarbons have been discovered and a petroleum system 

has been proven to exist. 

Exclusive Economic Zone (EEZ) — The maritime region adjacent to the territorial sea, extending 

200 nautical miles (nm) from the baseline of the territorial sea, in which the United States has exclusive 

rights and jurisdiction over living and nonliving natural resources. 

exploration — The process of searching for minerals preliminary to development. Exploration activities 

include: (1) geophysical surveys, (2) any drilling to locate an oil or gas reservoir, and (3) the drilling of 

additional wells after a discovery to delineate a reservoir. It enables the lessee to determine whether to 

proceed with development and production. 

exploration plan — A plan submitted by a lessee (30 CFR 250.33) that identifies all the potential 

hydrocarbon accumulations and wells that the lessee proposes to drill to evaluate the accumulations 

within the lease or unit area covered by the plan. All lease operators are required to obtain approval of 

such a plan by a BOEM Regional Supervisor before exploration activities may commence. 

field — Area consisting of a single reservoir or multiple reservoirs all grouped on, or related to, the same 

general geologic structural feature and/or stratigraphic trapping condition. There could be two or more 

reservoirs in a field that are separated vertically by impervious strata, laterally by geologic barriers, or 

both. 

formation — A bed or deposit sufficiently homogeneous to be distinctive as a unit. Each different 

formation is given a name, frequently as a result of the study of the formation outcrop at the surface and 

sometimes based on fossils found in the formation. 

geological data — Information derived from rocks of the seabed to provide information on the geological 

character of rock strata. 

geological surveys — Geological surveying on the Outer Continental Shelf consists of bottom sampling, 

shallow coring, and deep stratigraphic tests. These surveys provide data that are useful in determining the 

general geology of an area and whether the right types of rocks exist for petroleum formation and 

accumulation. 

geophysical data — Facts, statistics, or samples that have not been analyzed or processed, pertaining to 

gravity, magnetic, seismic, or other surveys/systems. 

geophysical surveys — Geophysical surveys on the OCS provide data about the seafloor and the 

subsurface. Comprised of 2-D and 3-D seismic surveys, as well as multi-component, high-resolution, 

wide-azimuth, and other advanced types of seismic surveys, the surveys obtain data for hydrocarbon 

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exploration and production, identify possible seafloor or shallow depth geologic hazards, and locate 

potential archaeological resources and hard bottom habitats that should be avoided. 

hurdle price — The price below which delaying exploration for the largest potential undiscovered field 

in the sale area is more valuable than immediate exploration. 

hydrocarbon — Any of a large class of organic compounds containing primarily carbon and hydrogen; 

comprising paraffins, olefins, members of the acetylene series, alicyclic hydrocarbons, and aromatic 

hydrocarbons; and occurring, in many cases, in petroleum, natural gas, coal, and bitumens. 

lease — A legal document executed between a landowner, as lessor, and a company or individual (as 

lessee) that conveys the right to explore the leased area for minerals or other resources on the OCS for a 

specified period of time. The term also means the geographic area covered by that authorization, 

whichever the context requires. 

lease sale — A BOEM proceeding by which leases of certain OCS tracts are offered for lease by 

competitive sealed bidding and during which bids are received, announced, and recorded. 

lease period — Duration of an OCS lease. Oil and gas leases are issued for a primary term of between 

5 and 10 years. After that, the term continues as long as there is production in paying quantities or if the 

lease is suspended. 

lessee — An entity, person, or persons to whom a lease is awarded; the recipient of a lease. 

liquefied natural gas (LNG) — Natural gas is converted to LNG by cooling it to a temperature 

of -

256°F, at which point it becomes a liquid. This simple process allows natural gas to be transported 

from an area of abundance to an area where it is needed. Once the LNG arrives at its destination, it is 

either stored as a liquid, or is converted back to natural gas and delivered to end-users. 

marine protected area — Any area of the marine environment that has been reserved by Federal, state, 

territorial, tribal, or local laws or regulations to provide lasting protection for part or all of the natural and 

cultural resources therein. 

minerals — Minerals include oil, gas, sulfur, and associated resources, and all other minerals authorized 

by an Act of Congress to be produced from public lands, as defined in Section 103 of the Federal Land 

Policy and Management Act of 1976. 

moratorium —Restriction on what areas BOEM can offer for OCS oil and gas leasing. 

natural gas — A mixture of hydrocarbon compounds and small quantities of various non-hydrocarbons 

existing in gaseous phase at the surface or in solution with crude oil in natural underground reservoirs at 

reservoir conditions. 

nearshore waters — Offshore waters that extend from the shoreline out to the limit of the territorial seas 

(12 nm). 

net social value — The discounted gross revenues from the produced oil and natural gas minus the 

private, environmental, and social costs required to realize the economic value of the resources. 

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net economic value (NEV) — The value to society that is derived from the resources in the ground. The 

NEV equals the discounted gross revenues from the produced oil and natural gas minus the private costs 

required to realize the economic value of the resources. 

Oil Spill Response Plan — A plan submitted to BSEE by the lease or unit operator prior to using a 

facility covered by the plan that details provisions for fully defined specific actions to be taken following 

discovery and notification of an oil spill occurrence (30 CFR part 254). 

Outer Continental Shelf (OCS) — All submerged lands seaward and outside the area of lands beneath 

navigable waters. Lands beneath navigable waters are interpreted as extending from the coastline to 3 nm 

into the Atlantic Ocean, the Pacific Ocean, the Arctic Ocean, Cook Inlet, and the Gulf of Mexico, 

excluding the coastal waters off Texas and western Florida. Lands beneath navigable waters are 

interpreted as extending from the coastline to 3 marine leagues into the Gulf of Mexico off Texas and 

western Florida. 

Operator (designated operator) — The person or company engaged in the business of drilling for, 

producing, or processing oil, gas, or other minerals and the designated operator is recognized by BOEM 

as the official contact and responsible party for the lease activities or operations. 

pelagic — Pertaining to the part of the open sea or ocean comprising the water column. 

petroleum — An oily, flammable, bituminous liquid that occurs in many places in the upper strata of the 

earth, either in seepages or in reservoirs; essentially a complex mixture of hydrocarbons of different types 

with small amounts of other substances; any of various substances (as natural gas or shale oil) similar in 

composition to petroleum. 

petroleum system — All of the geologic components and processes which create a suitable environment 

to generate, accumulate, and preserve oil and gas. Elements such as source rock, reservoir rock, and the 

trapping mechanism, along with fluids migration methods are necessary for the creation of a suitable 

hydrocarbon reservoir. 

planning area — An administrative subdivision of the OCS area used as the initial areas compared in the 

National OCS Program analyses. 

play (geologic play) — A group of known and/or postulated pools that share common geologic, 

geographic, and temporal properties, such as history of hydrocarbon generation, migration, reservoir 

development, and entrapment. 

pool — A discovered or undiscovered accumulation of hydrocarbons. 

production — Activities that take place after the successful completion of a well, including removal of 

minerals, field operations, transfer of minerals to shore, operation monitoring, maintenance, and workover 

drilling. 

primary production — The production of biomass from inorganic carbon and water through 

photosynthesis or chemosynthesis. The primary productivity of a marine community is its capacity to 

produce energy for its component species, which thus sets limits on the overall biological production in 

marine ecosystems. 

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USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Proposed Program — The second in a series of three proposed leasing schedules to be issued before a 

new National OCS Program may be approved. 

Proposed Final Program (PFP) — The third in a series of three leasing proposals developed before the 

Secretary of the Interior may take final action to approve the new National OCS Program. The PFP is 

submitted to the President and Congress, along with copies of the comments received on the Proposed 

Program, and responses to recommendations from the governors. 

Record of Decision (ROD) — The final step in the EIS process. The ROD identifies the selected 

alternative, presents the basis for the decision, identifies alternatives considered, specifies the 

environmentally preferable alternative, and provides information on appropriate mitigation measures. 

recoverable resources — Portion of the identified oil or gas resources that can be economically extracted 

under current technological constraints. 

rent — Periodic payments made by the holder of a lease, prior to production in paying quantities, for the 

right to use the land or resources for purposes established in the lease. 

Request for Information and Comments (RFI) — The first step in the development of a Program. 

BOEM publishes a Federal Register notice to request information and comments from states and local 

governments, tribal governments, Native American and Alaska Native organizations, Federal agencies, 

environmental and fish and wildlife organizations, the oil and gas industry, non-energy industries, other 

interested organizations and entities, and the general public for use in the preparation of the Program. 

BOEM seeks a wide array of information including information associated with the economic, social, and 

environmental values of all OCS resources, as well as the potential impact of oil and gas exploration and 

development on resource values of the OCS and the marine, coastal, and human environments. 

reservoir — Subsurface, porous, permeable rock body in which oil or gas or both may have accumulated. 

resource — Concentrations in the earth’s crust of naturally occurring liquid or gaseous hydrocarbons that 

can conceivably be discovered and recovered. Normal use encompasses both discovered and 

undiscovered resources. 

royalty — Payment, in value (money) or in kind, of a stated proportionate interest in production from 

mineral deposits by the lessees to the lessor. 

secondary production — Generation of biomass of consumer (heterotrophic) organisms. Its definition 

may be limited to include the consumption of primary producers by herbivorous consumers, but is more 

commonly defined to include all biomass generation by heterotrophs. 

seismic — Pertaining to, characteristic of, or produced by, earthquakes or Earth vibrations; having to do 

with elastic waves in the Earth. 

seismic survey — A method of geophysical prospecting using the generation, reflection, refraction, 

detection, and analysis of elastic waves in the Earth. Seismic surveys use sound waves that are sent 

through the ocean floor to map the subsurface. 

spudding — To begin drilling a well. 

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USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

stipulation — Specific measures imposed upon a lessee that apply to a lease. Stipulations are attached as 

a provision of a lease; they may apply to some or all tracts in a sale. For example, a stipulation might 

limit drilling to a certain time period of the year or certain areas. 

tract — An area of the seabed that may be offered for lease. It is a designation assigned, for 

administrative and statutory purposes, to a block or combination of blocks that are identified by an 

official protraction diagram prepared by BOEM. A tract may not exceed 5,760 acres unless it is 

determined that a larger area is necessary to comprise a reasonable economic production unit. 

trap — A geologic feature that permits the accumulation and prevents the escape of accumulated fluids 

(hydrocarbons) from the reservoir. 

unconventional recovery methods — Enhanced technological and engineering techniques used to 

produce oil and gas resources, such as horizontal drilling and hydraulic fracturing. 

unconventional resources — Oil and gas resources trapped in formations that have lower permeability 

and/or porosity than rocks that have typically produced oil and gas resources in the past. These 

formations are commonly referred to as shale or tight formations. In recent years, these types of 

formations have been increasingly produced using hydraulic fracturing. 

Undiscovered Economically Recoverable Resources (UERR) — The portion of the undiscovered 

technically recoverable resources that are economically recoverable under specified economic and 

technologic conditions, including prevailing prices and costs. 

Undiscovered Technically Recoverable Resources (UTRR) — Oil and gas that may be produced from 

the subsurface using conventional extraction techniques without any consideration of economic viability. 

well — A hole drilled or bored into the earth, usually cased with metal pipe, for the production of gas or 

oil a hole for the injection under pressure of water or gas into a subsurface rock formation. 

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Chapter 12 References 

Draft Proposal on the Size, Timing, and Location of OCS Lease Sales 

EIA (Energy Information Administration). 2017a. U.S. Crude Oil Production Forecast to Average 9.9 million 

Barrels per Day in 2018. Available online at https://www.eia.gov/petroleum/weekly/archive/2017/ 

170719/includes/analysis_print.php. Accessed July 31, 2017. 

EIA. 2017b. Annual Energy Outlook 2017. Available online at https://www.eia.gov/outlooks/aeo/pdf/ 

0383(2017).pdf. Accessed July 24, 2017. 

Chapter 1: OCS Oil and Gas Leasing Program Development Process 

BEA (Bureau of Economic Analysis). 2017. U.S. International Trade in Goods and Services, Exhibit 9. U.S. Trade 

in Petroleum and Non-Petroleum Products by End-Use. Available online at: https://www.bea.gov/ 

newsreleases/international/trade/2017/trad0517.htm. Accessed July 27, 2017. 

BOEM (Bureau of Ocean Energy Management). 2016. Assessment of Undiscovered Technically Recoverable Oil 

and Gas Resources of the Nation’s Outer Continental Shelf. Available online at https://www.boem.gov/ 

2016-National-Assessment-Fact-Sheet/. Accessed September 15, 2017. 

Boston Consulting Group. 2012. U.S. Manufacturing Nears the Tipping Point. Available online at 

http://doingwhatmatters.cccco.edu/portals/6/docs/US%20Mfg%20Nears%20Tipping%20Point.pdf. 

Accessed October 15, 2014. 

BSEE (Bureau of Safety and Environmental Enforcement). 2017. Outer Continental Shelf Oil and Gas Production: 

Yearly Oil and Gas Production. Available online at https://www.data.bsee.gov/Production/ 

OCSProduction/Default.aspx. Accessed July 25, 2017. 

Cummings, C. and R. Gold. Wall Street Journal Online. 2013. Rising U.S. Oil Output Gives Policy Makers More 

Options. Available online at http://online.wsj.com/news/articles/ 

SB10001424127887324682204578517271965827876. Accessed July 17, 2014. 

Dunnahoe, Tayvis. 2017. WoodMac: Deepwater Projects May Soon Compete with U.S. Tight-Oil Plays. Oil & 

Gas Journal. Available online at http://www.ogj.com/articles/2017/03/woodmac-deepwater-projects-maysoon-compete-with-us-tight-oil-plays.html. Accessed July 26, 2017. 

EIA (Energy Information Administration). 2015. EIA’s Monthly Energy Review, December 2015. Available 

online at http://www.eia.gov/totalenergy/data/monthly/index.cfm#consumption. Accessed 

December 23, 2015. 

EIA. 2017a. Total U.S. Energy Expenditures in 2015 were the Lowest in More Than a Decade. Available online 

at: https://www.eia.gov/todayinenergy/detail.php?id=32432. Accessed August 16, 2017. 

EIA. 2017b. Monthly Energy Review, June 28 2017. Available online at https://www.eia.gov/totalenergy/data/ 

monthly/index.php#consumption. Accessed July 25, 2017. 

EIA. 2017c. Annual Energy Outlook 2017. Available online at https://www.eia.gov/outlooks/aeo/pdf/ 

0383(2017).pdf. Accessed July 24, 2017. 

EIA. 2017d. U.S. Exports of Crude Oil and Petroleum Products Have More Than Doubled Since 2010. Available 

online at: https://www.eia.gov/todayinenergy/detail.php?id=31812. Accessed July 28, 2017. 

References 12-1 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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EIA. 2017e. U.S. Crude Oil Imports Increased in 2016. Available online at https://www.eia.gov/todayinenergy/ 

detail.php?id=30732. Accessed July 28, 2017. 

EIA. 2017f. Petroleum & Other Liquids: Crude Oil Production. Available online at http://www.eia.gov/dnav/pet/ 

pet_crd_crpdn_adc_mbblpd_a.htm. Accessed June 20, 2017. 

EIA. 2017g. Oil and Gas Supply. Available online at http://www.eia.gov/beta/aeo/#?id=14-AEO2017. Accessed 

June 20, 2017. 

EIA. 2017h. Natural Gas: Natural Gas Gross Withdrawals and Production. Available online at 

http://www.eia.gov/dnav/ng/ng_prod_sum_a_EPG0_FGW_mmcf_a.htm. Accessed July 5, 2017. 

EIA. 2017i. Annual Energy Outlook 2017. Natural Gas: Lower 48. Available online at https://www.eia.gov/ 

outlooks/aeo/data/browser/#/?id=14-AEO2017&cases=ref2017. Accessed June 20, 2017. 

Engel, R. and R. Windrem. How the US Oil, Gas Boom Could Shake Up Global Order, NBC News. Available 

online at http://www.cnbc.com/id/100606163. Accessed December 3, 2014. 

PwC. 2011. Shale Gas: A Renaissance in U.S. Manufacturing? Available online at http://www.pwc.com/en_US/ 

us/industrial-products/assets/pwc-shale-gas-us-manufacturing-renaissance.pdf. Accessed 

October 15, 2014. 

USGS (U.S. Geological Survey). 2013. Total Undiscovered Oil Resources, Total Mean Undiscovered Gas 

Resources. Available online at http://energy.usgs.gov/OilGas/AssessmentsData/ 

NationalOilGasAssessment/AssessmentUpdates.aspx. Accessed October 15, 2014. 

Chapter 2: Section 18 Factors for Consideration and Balancing 

Balcom B., D.C. Biggs, C. Hu, P. Montagna, and D.A. Stockwell. 2011. A Comparison of Marine Productivity 

Among Outer Continental Shelf Planning Areas. Prepared by CSA International, Inc. for the Department 

of the Interior, Bureau of Ocean Energy Management, Regulation, and Enforcement. Herndon, Virginia: 

OCS Study BOEMRE 2011-019. 

BOEM (Bureau of Ocean Energy Management). 2016. Draft Economic Analysis Methodology for the OCS Oil and 

Gas Leasing Program for 2017–2022. 

EIA (Energy Information Administration). 2017. Annual Energy Outlook (AEO) 2017. Available online at: 

https://www.eia.gov/outlooks/aeo/pdf/0383(2017).pdf. Accessed August 16, 2017. 

MMS (Minerals Management Service). 2007. Notice to Lessees and Operators (NTL) of Federal Oil and Gas 

Leases on the Outer Continental Shelf (OCS), Gulf of Mexico OCS Region. 

NRC (National Research Council). 1994. Environmental Information for Outer Continental Shelf Oil and Gas 

Decisions in Alaska. Available online at http://www.nap.edu/openbook.php?record_id=2353. Accessed 

August 20, 2015. 

Pomeroy, L. R. 1991. Relationships of Primary and Secondary Production in Lakes and Marine Ecosystems. Pages 

97–119 in J. Cole, G. Lovett and S. Findlay eds. Comparative Analyses of Ecosystems: Patterns, 

Mechanisms, and Theories. New York, New York: Springer. 

Chapter 3: Outreach, Coordination, and Consultation 

No references. 

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Chapter 4: Background, Leasing History, and Status of OCS Planning Areas 

ADNR (Alaska Department of Natural Resources). 2016. Annual Gross Oil Production. Available online at 

http://dog.dnr.alaska.gov/Information/Data. Accessed August 15, 2017. 

BOEM (Bureau of Ocean Energy Management). 2014. Atlantic OCS Proposed Geological and Geophysical 

Activities: Mid-Atlantic and South Atlantic Planning Areas. Programmatic Environmental Impact 

Statement. OCS EIS/EA BOEM 2014-001. February 2014. 

EIA (Energy Information Administration). 2017. Natural Gas: Alaska Dry Natural Gas Production. Available 

online at https://www.eia.gov/dnav/ng/hist/na1160_sak_2M.htm. Accessed December 4, 2017. 

Chapter 5: Valuation of Planning Areas 

BOEM (Bureau of Ocean Energy Management). 2014. Economic Inventory of Environmental and Social 

Resources Potentially Impacted by a Catastrophic Discharge Event within OCS Regions. October 2014. 

Available online at http://www.boem.gov/Economic-Inventories-for-CDE/. Accessed November 11, 2015. 

BOEM. 2016a. Assessment of Undiscovered Technically Recoverable Oil and Gas Resources of the Nation’s 

Outer Continental Shelf. Available online at https://www.boem.gov/National-Assessment-2016/. 

Accessed September 15, 2017. 

BOEM. 2016b. Economic Analysis Methodology for the 2017–2022 Outer Continental Shelf Oil and Gas Leasing 

Program. Available online at https://www.boem.gov/Economic-Analysis-Methodology/. Accessed 

September 7, 2017. 

EIA (Energy Information Agency). 2017. Annual Energy Outlook 2017. Available online at https://www.eia.gov/ 

outlooks/aeo/pdf/0383(2017).pdf. Accessed September 7, 2017. 

Industrial Economics, Inc. 2015. Consumer Surplus and Energy Substitutes for OCS Oil and Gas Production: The 

2015 Revised Market Simulation Model (MarketSim). BOEM Report 2015-054. Available online at 

https://www.boem.gov/Market-Simulation-Model/. Accessed July 26, 2017. 

Industrial Economics, Inc., and SC&A, Inc. 2015a. Forecasting Environmental and Social Externalities Associated 

with Outer Continental Shelf (OCS) Oil and Gas Development – Volume 1: The 2015 Revised Offshore 

Environmental Cost Model (OECM). U.S. Department of the Interior, Bureau of Ocean Energy 

Management. OCS Study BOEM 2015-052. 

Industrial Economics, Inc. and SC&A, Inc. 2015b. Forecasting Environmental and Social Externalities Associated 

with Outer Continental Shelf (OCS) Oil and Gas Development – Volume 2: Supplemental Information to 

the 2015 Revised Offshore Environmental Cost Model (OECM). U.S. Department of the Interior, Bureau 

of Ocean Energy Management. OCS Study BOEM 2015-053. 

Wolvovsky, E., and W. Anderson. 2016. OCS Oil and Natural Gas: Potential Lifecycle Greenhouse Gas Emissions 

and Social Cost of Carbon. U.S. Department of the Interior, Bureau of Ocean Energy Management. 

Sterling: Virginia. BOEM OCS Report 2016-065. 

Chapter 6: Planning Area Location Considerations 

ADF&G (Alaska Department of Fish and Game). 2014. Subsistence in Alaska, A Year 2012 Update. Available 

online at http://www.adfg.alaska.gov/static/home/subsistence/pdfs/vcsubsistence_update_2012.pdf. 

Accessed July 25, 2017. 

ASA (American Sportfishing Association). 2017. Economic Contributions of Recreational Fishing: U.S. 

Congressional Districts. February 2017. Available online at http://asafishing.org/uploads/ 

Congressional_District_Sportfishing_Impacts_2015_Report.pdf. Accessed September 14, 2017. 

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USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Alexander-Bloch, B. 2010. Vietnamese-American Fishers Fight for Oil Spill Claim Approval. New Orleans 

Times-Picayune. December 15, 2010. Available online at http://www.nola.com/news/gulf-oilspill/index.ssf/2010/12/vietnamese-american_fishermen.html. Accessed August 8, 2017. 

Auers, J., and R. Couture. 2015. If You’re Gonna Play in Texas, You Gotta Have a Fiddle (Coker) in the Band 

(Plant)–Or Maybe Not–The Changing Landscape of the PADD III Refining Environment. Available online 

at http://www.turnermason.com/index.php/if-youre-gonna-play-in-texas/. Accessed September 2, 2016. 

BOEM (Bureau of Ocean Energy Management). 2014. Economic Inventory of Environmental and Social 

Resources Potentially Impacted by a Catastrophic Discharge Event within OCS Regions. October 2014. 

Available online at http://www.boem.gov/Economic-Inventories-for-CDE/. Accessed November 11, 2015. 

BOEM. 2016. Cook Inlet Planning Area: Oil and Gas Lease Sale 244 in the Cook Inlet, Alaska. Final 

Environmental Impact Statement. December 2016. BOEM 2016-069. Available online at 

https://www.boem.gov/Cook-Inlet-Lease-Sale-244-Final-EIS-Volume-1/. Accessed August 3, 2017. 

BOEM. 2017. Gulf of Mexico OCS Oil and Gas Lease Sales: 2017-2022 Gulf of Mexico Lease Sales 249, 250, 

251, 252, 253, 254, 256, 257, 259, and 261. Final Multisale Environmental Impact Statement. OCS 

EIS/EA BOEM 2017-009. Available online at https://www.boem.gov/BOEM-EIS-2017-009-v1/. 

Accessed August 3, 2017. 

EIA (Energy Information Administration). 2012a. Oil: Crude and Petroleum Products Explained. Today in 

Energy. Available online at http://www.eia.gov/energyexplained/index.cfm?page =oil_imports. Accessed 

October 15, 2014. 

EIA. 2012b. Gasoline Explained: Regional Gasoline Price Differences. Available online at 

http//:www.eia.gov/Energyeplained/index.cfm?page=gasoline_regional. Accessed October 15, 2014. 

EIA. 2014. EIA’s U.S. Crude Oil Import Tracking Tool: Selected Sample Applications. Available online at 

http://www.eia.gov/petroleum/imports/samples/pdf/tracking_tool.pdf. Accessed November 1, 2014. 

EIA. 2015a. Effects of Removing Restrictions on U.S. Crude Oil Exports. September 2015. Available online at 

http://www.eia.gov/analysis/requests/crude-exports/pdf/fullreport.pdf. Accessed December 23, 2015. 

EIA. 2015b. Increases in U.S. Crude Oil Production are Predominantly Light, Sweet Crude. Available online at 

https://www.eia.gov/todayinenergy/detail.cfm?id=21512. Accessed October 9, 2015. 

EIA. 2016a. Today in Energy. February 18, 2016. Oil Production in Federal Gulf of Mexico Projected to Reach 

Record High in 2017. Available online at http://www.eia.gov/todayinenergy/detail.cfm?id=25012. 

Accessed June 20, 2016. 

EIA. 2016b. Annual Energy Outlook 2016. Full Release Date: End of August 2016. Available online at 

https://www.eia.gov/forecasts/aeo/index.cfm. Accessed August 23, 2016. 

EIA. 2017a. Petroleum & Other Liquids. U.S. Imports of Crude Oil. Available online at http://www.eia.gov/ 

dnav/pet/hist/LeafHandler.ashx?n=PET&s=MCRIMUS1&f=A. Accessed July 24, 2017. 

EIA. 2017b. U.S. Crude Oil Production Forecast to Average 9.9 Million Barrels per Day in 2018. Available online 

at https://www.eia.gov/petroleum/weekly/archive/2017/170719/includes/analysis_print.php. Accessed 

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Patterns of Primary Production. Continental Shelf Research. 13(5/6):575–599. 

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University of Alaska Sea Grant, AK-SG-99-03. 

Sturges, W., A. Lugo-Fernandez, and M.D. Shargel. 2005. Introduction. Pages 1–10 in Sturges W., and 

A. Lugo-Fernandez, eds. Circulation in the Gulf of Mexico Observations and Models. Washington, DC: 

American Geophysical Union. 

Thorsteinson, L.K., and Love, M.S., eds., 2016. Alaska Arctic Marine Fish Ecology Catalog: U.S. Geological 

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USCB. 2016b. Gulf Population Estimates. Available online at https://factfinder.census.gov/faces/ 

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tableservices/jsf/pages/productview.xhtml?fpt=table. Accessed July 27, 2017. 

USDA (United States Department of Agriculture). 2017. Permafrost Zones. Available online at 

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USEPA (United States Environmental Protection Agency). 2013. Climate Change Alaska: Climate Impacts in 

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USGCRP (United States Global Change Research Program). 2017. Regions and Topics. Available online at 

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Wilkinson, T., E. Wiken, J. Bezaury-Creel, T. Hourigan, T. Agardy, H. Herrmann, L. Janishevski, C. Madden, L. 

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References 12-15 January 2018 
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USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

APPENDIX A: SUMMARIES OF PUBLIC COMMENTS 

Summaries of Public Comments A-1 January 2018 
 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Table of Contents 

Appendix A Summaries of Public Comments by Commenter Category ....................................A-4 

A.1 Governors and State Agencies ............................................................................................A-14 

A.1.1 OCS Governors Coalition ................................................................................................................. A-14 

A.1.2 Alaska Region ................................................................................................................................... A-14 

A.1.3 Pacific Region ................................................................................................................................... A-15 

A.1.4 Gulf of Mexico Region ..................................................................................................................... A-18 

A.1.5 Atlantic Region ................................................................................................................................. A-19 

A.2 Local Governments.............................................................................................................A-23 

A.2.1 Alaska Region ................................................................................................................................... A-23 

A.2.2 Pacific Region ................................................................................................................................... A-24 

A.2.3 Gulf of Mexico Region ..................................................................................................................... A-25 

A.2.4 Atlantic Region ................................................................................................................................. A-26 

A.3 Public Interest Groups.........................................................................................................A-28 

A.4 Federal Agencies.................................................................................................................A-43 

A.5 Energy Exploration & Production Industry and Associations.............................................A-46 

A.6 Non-Energy Exploration & Production Industry and Associations ....................................A-48 

A.7 State-level Elected Officials................................................................................................A-68 

A.8 Members of Congress..........................................................................................................A-75 

A.9 Tribes and Tribal Organizations..........................................................................................A-77 

A.9.1 Alaska Region ................................................................................................................................... A-77 

A.9.2 Pacific Region ................................................................................................................................... A-78 

A.9.3 Gulf of Mexico Region ..................................................................................................................... A-80 

A.9.4 Atlantic Region ................................................................................................................................. A-81 

A.10 Form Letter Campaigns.......................................................................................................A-81 

A.11 General Public .....................................................................................................................A-89 

A.11.1 General Comments from Individuals Not Specific to OCS Program Areas...................................... A-89 

A.11.2 Comments from Individuals Specific to Program Areas................................................................... A-90 

Summaries of Public Comments A-2 January 2018 
 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Abbreviations and Acronyms 

AEWC Alaska Eskimo Whaling Commissions 

AOGA Alaska Oil and Gas Association 

API American Petroleum Institute 

AXPC American Exploration and Production Council 

BOEM Bureau of Ocean Energy Management 

CZM coastal zone management 

DNR Department of Natural Resources 

DOD Department of Defense 

EIS environmental impact statement 

FDEP Florida Department of Environmental Protection 

FR Federal Register 

GHG greenhouse gas 

GOM Gulf of Mexico 

IADC International Association of Drilling Contractors 

IAGC International Association of Geophysical Contractors 

ID identification 

IPAA Independent Petroleum Association of America 

Lt. Lieutenant 

NASA National Aeronautics and Space Administration 

NEPA National Environmental Policy Act of 1969 

NOAA National Oceanic and Atmospheric Administration 

NOIA National Ocean Industries Association 

OCS Outer Continental Shelf 

PESA Petroleum Equipment and Services Association 

TAPS Trans-Alaska Pipeline System 

USDOI U.S. Department of the Interior 

USOGA U.S. Oil and Gas Association 

Summaries of Public Comments A-3 January 2018 
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USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Appendix A Summaries of Public Comments by Commenter 

Category 

The Bureau of Ocean Energy Management (BOEM) requested information and comments on the 

2019–2024 Outer Continental Shelf (OCS) Oil and Gas Leasing Program Request for Information (RFI) 

in the Federal Register (FR) on July 3, 2017 (82 FR 30886). The RFI was distributed to interested and 

affected parties, including governors and Federal agency leaders, for a 45-day comment period. BOEM 

received approximately 815,000 comments on the RFI (see www.regulations.gov docket identification 

[ID] BOEM-2017-0050). A summary of substantive comments received on the RFI is provided below. 

Comments were received from several different types of stakeholders (see Table A-1). Of the 23 coastal 

states, BOEM received comment letters from 13 governors individually and/or as joint signatories 

(Alaska, Alabama, California, Delaware, Hawaii, Maine, Massachusetts, Mississippi, North Carolina, 

Oregon, Texas, Virginia, and Washington); 8 comments from state agencies where the governor did not 

comment separately (Connecticut, Florida, Georgia, Louisiana, Maryland, and New York), and 10 from 

state agencies in addition to the governor (Alaska, California, Delaware, Massachusetts, Texas, and 

Washington). In addition, BOEM received 32 comment letters from local governmental entities in 

10 states (Alaska, California, Florida, Louisiana, New Jersey, New York, North Carolina, South Carolina, 

Virginia, and Washington). 

Several form letter campaigns and petitions stated support for the development of a new National 

Program, while several were opposed. Each summary contains a Document ID. The Document ID refers 

to the comment submission’s docket number in the Federal government’s online comment website, 

www.regulations.gov, where the full comment submission can be accessed. 

Table A-1 shows the number of comment letters received, number of signatories on the comment letters, 

and the number of organizations that co-signed comment letters. Table A-2 provides a list of 

organizations that submitted comment letters. 

Summaries of Public Comments A-4 January 2018 
 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

TableA-1: Comment Letters Received by Commenter Type 

Commenter Type Number of Letters 

Received 

Number of 

Signatories on Letter 

Number of 

Organizations that 

Co-signed Letter 

Governors and State 

Agencies 32 39 -

Local Governments 32 - -

Public Interest Groups 82 - 269 

Federal Agencies 10 - -

Energy Exploration & 

Production Industry and 

Associations 

10 - 16 

Non-energy Exploration & 

Production Industry and 

Associations 

107 - -

State-level Elected 

Officials 39 167 -

Members of Congress 12 376 -

Tribes and Tribal 

Organizations 22 - -

General Public 464 - -

Petitions 23 1,258,929 -

Form Letters 568,865 - -

Note: To avoid double-counting, the numbers shown in bold font were summed to determine the total comments 

received, which was 1,828,891. 

Summaries of Public Comments A-5 January 2018 
 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Table A-2: List of Commenters 

Commenter Type Organization 

Governors and State Alaska Governor 

Agencies Alaska Department of Natural Resources 

Alabama Governor 

California Attorney General 

California Coastal Commission 

California Fish and Game Commission 

California State Lands Commission 

Connecticut Department of Energy and Environmental Protection 

Delaware Governor 

Delaware Department of Natural Resources and Environmental Protection 

Florida Department of Environmental Protection, Department of State, Florida Fish and 

Wildlife Conservation Commission, Florida Geological Survey, and Treasure Coast 

Regional Planning Council 

Georgia Department of Natural Resources 

Hawaii Governor 

Louisiana Department of Natural Resources 

Maryland Attorney General 

Maryland Department of Natural Resources 

Massachusetts Governor 

Massachusetts Attorney General 

Massachusetts Energy and Environmental Affairs, Coastal Zone Management 

North Carolina Governor 

North Carolina Lt. Governor 

New Jersey Department of Environmental Protection 

New York Attorney General, Environmental Protection Bureau 

New York Departments of State and Environmental Conservation and Energy Research 

and Development Authority 

OCS Governors Coalition—Alabama, Alaska, Maine, Mississippi, Texas 

Oregon Governor 

Texas Railroad Commission Chair 

Texas Railroad Commissioner Christian 

Texas Railroad Commissioner Sitton 

Virginia Governor 

Virginia Lt. Governor 

Washington Departments of Ecology, Natural Resources, Fish and Wildlife 

West Coast Governors—California, Oregon, Washington 

Local Governments Alaska—North Slope Borough 

California—City of San Luis Obispo 

California—City of Santa Barbara 

California—Santa Barbara County 

California—Santa Barbara Air Pollution Board 

California—Ventura County 

Florida—Coconut Creek 

Florida—Martin County 

Florida—Miami-Dade County 

Florida—Monroe County 

Florida—Pinellas County 

Florida—St. Lucie County 

Louisiana—Great Lafourche Port Commission 

Louisiana—Madison Parish Port Commission 

New Jersey—Borough of Avalon 

Summaries of Public Comments A-6 January 2018 
 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Commenter Type Organization 

Local Governments New Jersey—Borough of Stone Harbor 

(continued) New Jersey—Cape May County 

New York—Brookhaven, Long Island 

North Carolina—Bald Head Island 

North Carolina—Caswell Beach 

North Carolina—Duck 

North Carolina—Kill Devil Hills 

North Carolina—Southport Mayor 

North Carolina—Southport Alderman 

North Carolina—Sunset Beach 

South Carolina—Georgetown County 

South Carolina—Hilton Head Island 

South Carolina—Horry County 

South Carolina—Seabrook Island 

South Carolina—Sullivan’s Island 

Virginia—Virginia Beach 

Washington—North Pacific Coast Marine Resources Committee 

Public Interest Groups Alaska Eskimo Whaling Commission, Jessica Lefevre 

Alaska Marine Conservation Council, Kelly Harrell 

Albermarle Garden Club, Carter 

Americans For Prosperity, Jeremy Price 

Association to Preserve Cape Cod, Don Keeran 

Atlantic States Marine Fisheries Commission, Lisa Havel 

Audubon California, Michael Lynes 

Camden Creek HOA, Rick Hoffman 

Cars Are Basic, Scott Wenz 

Center for a Sustainable Coast, David Kyler 

Center for Biological Diversity, Earthjustice, Gulf Restoration Network, Sierra Club, 

Kristen Monsell 

Center for Regulatory Effectiveness, Scott Slaughter 

Cetacean Society International, William Rossiter 

Chesapeake Bay Foundation, Chris Moore 

Clean Ocean Action, Cindy Zipf 

Coastal Carolina Riverwatch, Larry Baldwin and James Corner 

Coastal Coordination Program of The Ocean Foundation, Richard Charter 

Committee of 100 for Economic Develop, Inc., Michael Olivier 

Consumer Energy Alliance, Dave Holt 

Consumer Energy Alliance—Florida, Kevin Doyle 

Earthjustice, Erik-Grafe 

Edisto Island Community Association, Fred Palm 

Energy Institute of Alabama, Blake Hardwich 

Environmental Defense Center, at al., Kristen Hislop 

Florida Wildlife Federation, Manley K. Fuller 

Friends of the Earth – US, Gary Hughes 

Georgia AgriBusiness Council, Bryan Tolar 

Georgia Conservancy, Charles McMillan 

Gulf Economic Survival Team, Lori LeBlanc 

Greenpeace USA, Timothy Donaghy 

Indivisible Northampton County, Joe Guest 

Jersey Shore Partnership, Margot Walsh 

League of Women Voters of Carteret County, Carol Geer 

League of Women Voters of North Carolina, Margaret Salinger 

League of Women Voters of the Lower Cape Fear, NC, Clarice Reber 

Summaries of Public Comments A-7 January 2018 
 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Commenter Type Organization 

Public Interest Groups League of Women Voters of New Jersey, Nancy Hedinger 

(continued) Lynnhaven River NOW, Karen Forget 

Los Angeles Waterkeeper, Jeannette Baudelaire 

ManaSota-88, Inc., Glenn Compton 

Mid-Atlantic Fishery Management Council, Jessica Coakley 

Mississippi Energy Institute, Patrick Sullivan 

National Audubon Society, Sarah Greenberger 

National Parks Conservation Association 

Natural Resources Defense Council, Alexandra Adams 

New England Fishery Management Council, John Quinn 

New England Fishery Management Council, Thomas Nies 

New Jersey Conservation Foundation, Alison Mitchell 

New Jersey Council of Diving Club, John Fullmer 

North Carolina Coastal Federation, Ana Zivanovic-Nenadovic 

North Carolina Council of Churches, Jennifer Copeland 

Northwest Atlantic Marine Alliance, Amy MacKown 

Ocean Conservancy, Nat. Audubon Society, Pew Charitable Trusts, WWF, Oceana, 

Andrew Hartsig 

Oceana – Florida, Erin Handy 

Oceana – South Carolina, Samantha Siegel 

Oceana – Georgia, Samantha Siegel 

Oceana - Delaware, Samantha Siegel 

Oceana - Maryland, Caroline Wood 

Oceana - North Carolina, Randy Sturgill 

Oceana - Virginia, Caroline Wood 

Oceana, Jacqueline Savitz 

One Hundred Miles, Alice Keyes 

One More Generation, Olivia Ries 

Plastic Ocean Project, Inc., Bonnie Monteleone 

Santa Barbara Channelkeeper, Kira Redmond 

SC Environmental Law Project, Ameilia Thompson 

Securing America’s Future Energy (SAFE), Alexander Adams 

Sierra Club, Michael Brune 

Sierra Club - Croatan Group, Michael Murdoch 

South Atlantic Fishery Management Council, Michelle Duval 

South Carolina Wildlife Federation, Steve Gilbert 

Southern Alliance for Clean Energy, Chris Carnevale 

Southern Environmental Law Center on behalf of Cape Fear River Watch, et al., 

Sierra Weaver 

Surfrider Foundation, Katie Day 

Surfrider Foundation, Outer Banks Chapter, Matt Walker 

Texas Conservative Coalition Research, John Colyandro 

The CLEO Institute, Caroline Lewis 

The Nature Conservancy, Stephanie Bailenson 

The Wilderness Society, Lois Epstein 

Turtle Island Restoration Network, Andrew Ogden 

Voces Verdes, Adrienna Quintero 

Wildlife Conservation Society (WCS), Angela Noakes 

World Wildlife Fund – U.S. Arctic Program, Margaret Williams 

Federal Agencies Department of Commerce and National Oceanic and Atmospheric Administration 

Department of Defense 

Department of Homeland Security—United States Coast Guard 

Department of Justice 

Summaries of Public Comments A-8 January 2018 
 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Commenter Type Organization 

Federal Agencies Department of State 

(continued) Department of Transportation 

Marine Mammal Commission 

National Aeronautics and Space Administration 

National Marine Fisheries Service, Alaska Region 

United States Environmental Protection Agency 

Energy Exploration & 

Production Industry 

and Associations* 

American Petroleum Institute (API), National Ocean Industries Association (NOIA), 

Independent Petroleum Association of America (IPAA), United States Oil and Gas 

Association (USOGA), American Exploration & Production Council (AXPC), 

International Association of Drilling Contractors (IADC), International Association of 

Geophysical Contractors (IAGC), Alaska Oil and Gas Association (AOGA) Petroleum 

Equipment and Services Association (PESA) 

Anadarko Petroleum Corporation 

Arctic Slope Regional Corporation (ASRC) Exploration, LLC (AEX) 

BP Exploration & Production Inc. 

Chevron U.S.A., Inc. 

*One proprietary 

comment not listed or 

summarized. 

Cobalt International Energy 

Diamond Offshore 

Enven Energy Ventures 

Shell Offshore 

Statoil USA E & P, Inc. 

Airlines for America, John Hiemlich 

Non-Energy Alaska Chamber, Curtis Thayer 

Exploration & Alaska Chamber of Commerce, et al., Christopher Guith 

Production Industry Alaska District Council of Laborers, A.J. Merrick 

and Associations Alaska Longline Fisherman’s Association, et al., Karen Gillis 

Alaska Maritime Agencies, Luke Hasenbank 

Alaska Trucking Association, Aves Thompson 

Alyeska Pipeline Service Co., Tom Barrett 

American Chemistry Council, Owen Kean 

American Forest & Paper Association, Jerry Schwartz 

American Highway Users Alliance, Gregory Cohen 

American Iron and Steel Institute (AISI), Thomas J. Gibson 

American Society of Landscape Architects, Nancy Somerville 

Associated General Contractors of Alaska, John MacKinnon 

Associated Industries of Florida, Brewster Bevis 

Bald Head Association, Judy Porter 

Bayou Industrial Group (BIG), Denny Borne 

C + L Creative, Laura Butcher 

Cape May County Chamber of Commerce, Vicki Clark 

Carteret County Chamber of Commerce, Tom Kies 

Caterpillar Inc., Wayne Zemke 

Chemical Industry Council of Illinois, Mark Biel 

Chickasaw Distributors, Inc., Brad Baker 

Clay County Chamber of Commerce, Doug Conkey 

Committee of 100 for Economic Development, Inc., Michael Olivier 

COOL Environmental Consulting, Patrick Cotter 

Covington County Chamber of Commerce, Marie Shoemake 

Dare County Tourism Board and Outer Banks Visitors Bureau, Susie Walters and 

Lee Nettles 

Elite Parking, Dane Grey 

Energy Industries of Ohio, Robert M. Purgert 

Ensco, Brady 

Garden Club of Virginia, Wendy Vaughn 

Summaries of Public Comments A-9 January 2018 
 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Commenter Type Organization 

Non-Energy Gate Petroleum Company, Buzz Hoover 

Exploration & Georgia Chamber of Commerce, Clark 

Production Industry Georgia Association of Manufacturers, G.L. Bowen 

and Associations 

(continued) 

Greater Iberia Chamber of Commerce, Janet Faulk Gonzales 

Greater New Orleans Inc., Michael Hecht 

Greater Port Arthur Chamber of Commerce, William McCoy 

Greater Tomball Area Chamber of Commerce, Bruce Hillegeist 

Hooper Family Seafood, Penny Hooper 

Houma-Terrebonne Chamber of Commerce, Suzanne Nolfo Carlos 

Illinois Chamber of Commerce, Katie Stonewater 

Industrial Energy Consumers of America, Paul Cicio 

Jacksonville Axemen Rugby League, Drew Slover 

JAX Chamber, Christopher Quinn 

Lime Instruments, Rob Stewart 

Louisiana Mid-Continent Oil Gas Association and the Louisiana Association of 

Business and Industry, Lori LeBlanc 

Louisiana Oil Marketers Convenience Store Association, Natalie Isaacks 

Lynden Inc., Jeanine St John 

Manufacture Alabama, George Clark 

Marine & Industrial, Steve Barker 

Mexico Beach Charters, BBT, LLC, Recreational Fishing Alliance-Forgotten Coast 

Chapter, Capt., Tom Adams 

Mississippi Farm Bureau Federation, A. Whittington 

Mississippi Manufacturers Association, Jay Moon 

Mobile Area Chamber of Commerce, William Sisson 

National Association of Charterboat Operators, Capt. Bob Zales, II 

National Association of Manufacturers, Ross Eisenberg 

NACS, Paige Anderson 

New Orleans Chamber of Commerce, G. Ben Johnson 

North Star Terminal & Stevedore Co LLC, Scott Vierra 

North Star Terminal & Stevedore Co LLC, Steven Post 

Ohio AgriBusiness Association, Christopher Henney 

Ohio Cast Metals Association, Kevin Schmidt 

One Acadiana, Andre Breaux 

Pacific Drilling Services Inc. 

Panama City Boatmen Association, Capt. Bob Zales, II 

Partnership for Affordable Clean Energy, Laura Schepis 

Peassal Operating Company, Peassal 

Petroleum Marketers Association of America, Rob Underwood 

Pink Petro, Katie Mehnert 

Ports Association of Louisiana, David Allain 

Public Lands Council, Dave Eliason 

Resource Development Council, Carl Portman 

Rig-Chem, LLC, Lori Davis 

Rowan Companies, Michael Lawson 

Saltchuk, Harry McDonald 

Sealark Investments, Inc., John Schwarz, Jr. 

SolstenXP, Inc., Jesse Mohrbacker 

South Carolina Chamber of Commerce, Ted Pitts 

South Carolina Manufacturers Alliance, Lewis Gossett 

South Central Industrial Association, Jane Arnette 

Southern Chemical Corporation, Jan Spin 

South Louisiana Economic Council, Vic Lafont 

Summaries of Public Comments A-10 January 2018 
 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Commenter Type Organization 

Non-Energy St. Mary Chamber of Commerce, Donna Meyer 

Exploration & St. Tammany West Chamber of Commerce, Lacey Toledano 

Production Industry Steel Tank Institute-Steel Plate Fabricators Association, Wayne Geyer 

and Associations 

(continued) 

Steve Pratt Enterprises, Steve Pratt 

Texas Association of Business, Stephen Minick 

Texas Association of Manufacturers, Richard Bennett 

Texas Trucking Association 

Teyatech Inc., Ron Perry 

The Plaza Group, Randy Velarde 

The Town Dock, Katie Almeida 

The State Chamber of Commerce Mississippi Economic Council, Scott Waller 

Thibodaux Chamber of Commerce, Cody J Blanchard 

Transocean, Bond 

Transportation Institute, Andrew Strosahl 

Udelhoven Oilfield System Services, Inc., Jim Udelhoven 

Virginia Beach Hotel Association, Diana Burke 

Virginia Beach Restaurant Association, Laura Habr William Gambrell 

Virginia Chamber of Commerce, Barry DuVal 

Virginia Manufacturers Association, Brett Vassey 

Virginia Petroleum Council, Miles Morin 

Vivlamore Companies, Frontier Supply Company, Sunrise Bagel & Espresso, MV 

Investments, The Showcase, Regency Fairbanks Hotel, Tubby’s, Bill Vivlamore 

W. D. Scott Group, Inc., William Scott 

Wisconsin Industrial Energy Group 

Wrightsville Beach Chamber of Commerce, Susan Bulluck 

State-level Elected 14 Members of the North Carolina House of Representatives 

Officials Alabama State House of Representatives, Lynn Greer 

Alabama State House of Representatives, Victor Gaston 

Alabama State Senator, Steve Livingston 

Alabama State House of Representatives, David R. Sessions 

Alaska State House of Representatives, Charisse Millet 

Alaska State House of Representatives, Chris Birch 

Alaska State Senate, Cathy Giessel 

Alaska State Senate, John Coghill 

Alaska State Senate, Pete Kelly 

Alaska State Senate, Kevin Meyer 

California State Senate, Daniel Alavarez 

California State Senate, Senator Mike McGuire 

Energy Producing States Coalition, Senator Chuck Winder 

Florida House of Representatives, Jason Fischer 

Georgia State Senator Frank Ginn 

Georgia State House of Representatives, Don Parsons 

Georgia State House of Representatives, Jason Spencer 

Georgia State Representative, Charles Martin 

Mississippi State Senate, Angela Burks Hill 

Mississippi State House of Representatives, Gary V. Staples 

Mississippi State Senate, Charles Younger 

Mississippi State Senate, Terry Burton 

New Jersey General Assembly, Timothy Eustace 

New Jersey State Senate, Bob Smith 

New Jersey 11th Legislative District Monmouth County, Eric Houghtaling and 

Joann Downey 

South Carolina General Assembly, Chip Campsen III. 

Summaries of Public Comments A-11 January 2018 
 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Commenter Type Organization 

State-level Elected South Carolina House of Representatives, Jason Elliott 

Officials South Carolina House of Representatives, Lee Hewitt 

South Carolina House of Representatives, Bill Sandifer 

South Carolina State Senate, George Campsen 

South Carolina State Senate, Paul G. Campbell 

Texas State House of Representatives, Dennis Paul 

Texas State Senate, Craig Estes 

Texas State Senate, Don Huffines 

Texas State House of Representatives, Brooks Landgraf 

Virginia Environment and Renewable Energy Caucus, Alfonso Lopez 

Virginia State Senate, Frank W. Wagner 

Wyoming State Senate, Eli Bebout 

Members of Congress Thirty-Six Senators: Murkowski (AK), Cassidy (LA), Cornyn (TX), Strange (AL), 

Capito (WV), Barrasso (WY), Risch (ID), Hatch (UT), Sullivan (AK), Lee (UT), 

Wicker (MS), Gardner (CO), Inhofe (OK), Enzi (WY), Kennedy (LA), Boozman (AR), 

Crapo (ID), Daines (MT), Tillis (NC), Flake (AZ), Cotton (AR), Alexander (TN), 

Cruz (TX), Blunt (MO), Hoeven (ND), Rounds (SD), Heller (NV), Thune (SD), 

Shelby (AL), Isakson (GA), Portman (OH), Young (IN), Burr (NC), Lankford (OK), 

Roberts (KS), Cochran (MS) 

Thirty Senators: Merkley (OR), Markey (MA), Menendez (NJ), Booker (NJ), Nelson (FL), 

Whitehouse (RI), Blumenthal (CT), Franken (MN), Shaheen (NH), Cardin (MD), 

Cantwell (WA), Baldwin (WI), Wyden (OR), Van Hollen (MD), Feinstein (CA), 

Gillibrand (NY), Reed (RI), Warren (MA), Duckworth (IL), Hassan (NH), Murray (WA), 

Harris (CA), Peters (MI), Sanders (VT), Hirono (HI), Durbin (IL), Leahy (VT), 

Brown (OH), Stabenow (MI), Cortez Masto (NV) 

120 Members of the U.S. House of Representatives Committee on Natural Resources 

103 Members of Congress 

75 Members of Congress: Breakdown of signatories by state: AZ-2, CA-17, CO-2, DC, FL3, HI, IL-6, KY, MA-3, MD-2, ME, MI2, MN, MO, NC-2, NJ-2, NV, NY-7, OR-2, PA-2, 

RI, TN, TX, VA-4, VT, WA, WI 

68 Members of Congress: Breakdown of signatories by state: AZ, CA-8, CO, FL-8, GA, 

IL-2, KY, MA-5, MD-2, ME, MN-2, MO, NC-4, NH-2, NJ-9, NY-7, OR-2, PA-3, RI, SC, 

TN, VA-4, VT 

39 Members of Congress: Breakdown of signatories by state: AZ, CA-20, CO, DC, HI, 

KY, MA, MD, MI, MN, NJ, NY, OR-4, RI, VA, WA-2 

10 Members of Congress: Costa (CA-16), Richmond (LA-2), Lee (TX-18), 

Bennie Thompson (MS-2), Gonzalez (TX-15), Green (TX-29), Peterson (MN-7), 

Sewell (AL-7), Plaskett (VI), Veasey (TX-33) 

Senator Bill Nelson, Florida 

Congresswoman Kathy Castor, Florida 

Congressman Donald McEachin, Virginia 

Congressman Tom Rice, South Carolina 

Tribes and Tribal Arctic Inupiat Offshore, LLC 

Organizations Arctic Slope Regional Corporation 

Bering Sea Elders Group and Association of Village Council Presidents 

Blue Lake Rancheria 

Bristol Bay Native Association 

Confederated Tribes of Coos, Lower Umpqua & Siuslaw Indians 

Coquille Indian Tribe 

Federated Indians of Graton Rancheria 

Gullah/Geechee Nation 

Kashia Band of Pomo Indians of the Stewart’s Point Rancheria 

Kawerak, Inc. 

Makah Tribe 

Summaries of Public Comments A-12 January 2018 
USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Commenter Type Organization 

Tribes and Tribal Makah Tribal Council 

Organizations Native Village of Savoonga 

Native Village of Shishmaref 

Native Village of St. Michael 

Northern California Tribal Chairmen’s Association 

Olgoonik Corporation, The Native Village Corporation for Wainwright, Alaska 

Quileute Tribal Council 

San Luis Rey Band of Mission Indians 

Santa Ynez Band of Chumash Indians 

Scotts Valley Band of Pomo Indians 

Form Letter Friends of the Earth (Megan Coglianese) 

Campaigns CREDO 

Friends of the Earth 

Sierra Club 

Center for Biological Diversity 

Ocean Conservancy 

Consumer Energy Alliance 

Food and Water Watch 

Audubon California 

Oceana (1) 

Oceana (2) 

Wildlife Conservation Society 

Conservation Voter of South Carolina 

Alaska Wilderness League 

NRDC 

The Pew Charitable Trusts 

Surfrider Foundation 

Veterans 

World Wildlife Fund 

Environment America 

Earthjustice 

Oil Change International 

Save Our Sea NC 

Sierra Club-Virginia Chapter 

Southern Alliance for Clean Energy 

Virginia Petroleum Council 

Greenpeace USA 

North Carolina League of Conservation Voters 

North Carolina Conservation Network 

Climate Writers 

Joe Jansen 

Virginia League of Conservation Voters 

Campaign A 

Environmental Action 

Campaign B 

David Bennett 

Kristen Brown 

Peter Smith 

Lacey Hicks 

Shane Farnor 

Elizabeth Slikas 

Greater Port Arthur Chamber of Commerce, William McCoy 

NCLCV 

Summaries of Public Comments A-13 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Commenter Type Organization 

Form Letter Campaign C 

Campaigns Southern Chemical Corporation 

Thomas Jefferson Institute for Public Policy, et al 

Note: Individual commenters from the general public are not listed; see Section A.1.11 for a summary of comments 

from the general public. 

A.1 GOVERNORS AND STATE AGENCIES 

A.1.1 OCS Governors Coalition 

OCS Governors Coalition 

Document ID: BOEM-2017-0050-49664 

The OCS Governors Coalition was created by governors from coastal states in May 2011 to promote 

constructive dialogue on OCS energy resource planning and development between coastal state governors 

and Federal policy makers. The bipartisan group of governors supports policies that encourage a safe, 

responsible expansion of offshore oil, natural gas, and renewable energy development to the benefit of the 

nation, their states, and the citizens. The Coalition’s comment letter, signed by Governors Paul LePage of 

Maine, Kay Ivey of Alabama, Phil Bryant of Mississippi, Greg Abbott of Texas, and Bill Walker of 

Alaska, states that they believe it is prudent to include all leasing options in the Draft Proposed Program, 

understanding that circumstances affecting leasing decisions could change during the course of the 

program’s development and implementation. The Coalition believes that access to offshore energy 

resources will allow coastal states and communities to realize great economic opportunities and that the 

successful development of the Gulf of Mexico and the initial exploration of Alaska’s OCS demonstrate 

how responsible offshore energy development can generate many good paying jobs, spur activity in a host 

of associated industries, and generate billions of dollars in tax revenue. The Coalition also believes that 

states must have an up-to-date assessment of the potential resource base off their coasts to inform 

decisionmaking regarding offshore development and, thus, welcome the decision to reevaluate permits to 

conduct seismic surveys in the Mid- and South Atlantic. The Coalition also strongly urges the 

Administration to support existing revenue sharing with states, as well as any legislative efforts to expand 

revenue sharing to all participating coastal states. Further, they urge that the existing revenue sharing cap 

for the Gulf states be lifted. 

A.1.2 Alaska Region 

Alaska Governor Bill Walker 

Document ID: BOEM-2017-0050-49697 

The governor supports responsible leasing and activity in the OCS, grounded in community input and 

robust environmental protection. The governor notes that it is a state priority and fundamentally 

consistent with its laws, goals, and policies. The governor attached his letter of October 6, 2016, in which 

he “unambiguously express[ed] the State’s interest in including sales in the Beaufort and Chukchi OCS 

areas” as they were not included in the 2017–2022 Program with Cook Inlet, the third area that the 

governor nominated in his earlier letter. 

Summaries of Public Comments A-14 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Alaska Department of Natural Resources 

Document ID: BOEM-2017-0050-49612 

The Alaska Department of Natural Resources (DNR) believes at least three lease sales should be 

conducted in each of the three primary Alaskan OCS areas—the Chukchi Sea, the Beaufort Sea, and Cook 

Inlet—during the 2019–2024 period. DNR states that this will allow interest to be gauged over the course 

of the program and allow multiple opportunities for the state and Federal government to benefit from 

potential leasing activity. DNR states that Arctic OCS leasing, and potential subsequent development 

activity, has a number of ecological and community considerations that must be taken into account, but 

ultimately has important economic, social, and environmental benefits from the state perspective. DNR 

states that offshore development in Cook Inlet has supplied a substantial amount of Alaska’s community 

energy needs. DNR states that inherent in the statutory direction of sharing benefits across regions is that 

there is some activity in prospective regions that support development when environmental risks can be 

appropriately mitigated. Instead of this balance, the most recently developed BOEM OCS oil and gas 

leasing program for 2017–2022 saw no lease sales in the northern Arctic and only one within the Cook 

Inlet area for the entire five-year period. DNR states that rather than no leasing at all that completely 

deprives the nation and the state from sharing in the statutorily recognized benefits of development, an 

equitable balance must be established that sees lease sales offered in the Arctic. DNR states that in 

Alaska, there is currently little offshore commerce or transit, and correspondingly limited support 

infrastructure. DNR states that any developments need to consider and support the continued ecological 

use of the OCS by local communities, but there are significant state and national benefits in establishing a 

more robust network in the Arctic. DNR states that measured and regulated OCS development is 

fundamentally consistent with Alaska’s laws and essential to support the state’s long-term goals of 

providing a robust economic and civic base for its residents and that the Trans-Alaska Pipeline System 

(TAPS) serves as the state’s economic backbone and a globally impactful piece of the national 

infrastructure. DNR states that identifying new resource potential through leasing and exploration to 

support its continued efficient operation is one of the foremost goals of the state and that the presence of 

the existing extensive oil and gas infrastructure on the North Slope further supports the state goal of OCS 

activity that increases Alaska’s employment opportunities and supports the nation’s export of energy to 

partners and allies around the world. 

A.1.3 Pacific Region 

California Attorney General 

Document ID: BOEM-2017-0050-49583 

The California Attorney General expresses strong opposition to inclusion of any California planning area 

in the new National Program. Interior last conducted a sale for Federal tracts offshore California in 1984, 

and Interior last included California planning areas in a National program in the 1987–1992 Program. 

The Attorney General notes that this lack of leasing of areas offshore California has not posed an obstacle 

to the development of plentiful supplies of domestic oil and gas. The Attorney General is not aware of 

any evidence that the oil and gas industry has significant interest in again attempting to explore and 

develop offshore California, stating that industry has shown this lack of interest in several ways, including 

that the major oil companies that leased tracts offshore California in the 1980s have largely given up their 

leases and operations. The Attorney General notes that any company seeking to develop offshore of 

California would also face a challenging regulatory environment. The Attorney General notes that the 

California Coastal Commission implements California’s federally approved coastal management program 

Summaries of Public Comments A-15 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

and is thus the California state agency with regulatory authority over offshore leasing, exploration, and 

development and production. The Attorney General notes that Interior will have to determine that it is 

conducting lease sales for areas offshore California in a manner that is fully consistent with the state’s 

coastal management program, and lessees also will have to certify that their activities are consistent with 

the program. The Attorney General notes that the Coastal Commission has articulated in the past that it is 

difficult for it to understand how it could find that construction and operation of new hazardous 

infrastructure both offshore California and along California’s splendid coast is consistent with the coastal 

program and that many coastal local governments have made express their opposition to onshore support 

facilities. 

California Coastal Commission 

Document ID: BOEM-2017-0050-46653 

The California Coastal Commission steadfastly opposes any new leasing in “frontier” areas of the OCS, 

noting that activities in undeveloped areas off California would require new platforms, offshore and 

onshore pipelines, and other infrastructure that would likely cause significant adverse effects on coastal 

resources. The Commission states that producing oil and gas in these areas could have significant, 

longterm, and far-reaching effects on marine and coastal wildlife, commercial fishing, wetlands, ocean 

and beach users, and coastal tourism and that additional offshore oil production increases the risk of an oil 

spill occurring and potentially causing devastating state-wide environmental and economic impacts. The 

Commission states that expanded use of fracking and other well-stimulation treatments could result in 

chemical discharges that harm marine resources and that producing oil and gas also results in significant 

emissions of carbon pollution (greenhouse gases), thereby contributing to climate change and rising sea 

levels, all of which threaten many of the resources integral to the California coast. The Commission 

states that new onshore infrastructure and facilities to support offshore oil and gas development could 

have adverse impacts on water quality, agricultural lands and uses, recreation, environmentally sensitive 

habitat areas, scenic vistas, and archeological resources. The Commission is the agency with CZM 

regulatory authority and thinks it is difficult to see how the construction and operation of new hazardous 

industrial infrastructure offshore and along California’s magnificent coast could be approved consistent 

with California’s coastal protection laws. 

California Fish and Game Commission 

Document ID: BOEM-2017-0050-49719 

The California Fish and Game Commission passed a resolution on June 22, 2017, supporting the 

prohibition of oil and gas leasing in Federal waters off California. 

California State Lands Commission 

Document ID: BOEM-2017-0050-49721 

The California State Lands Commission vociferously opposes any new oil and gas leasing in the Pacific 

OCS as such development poses a threat to California’s ocean and marine environment and economy. 

The Commission manages oil and gas resources in state waters and noted that a new lease has not been 

issued since 1968. 

Summaries of Public Comments A-16 January 2018 
 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

California Governor Jerry Brown, Oregon Governor Kate Brown, and 

Washington Governor Jay Inslee (West Coast Governors Coalition) 

Document ID: BOEM-2017-0050-49578 

The governors of California, Oregon, and Washington express their strong opposition to the inclusion of 

any new proposed oil and gas lease sale off their shared coast. The governors noted that the states’ people 

understand the looming catastrophe of climate change that requires the Nation to move away from fossil 

fuel consumption to a more prosperous, sustainable and clean energy economy. The governors note that 

the states played a leadership role in the establishment of the U.S. Climate Alliance—a coalition of states 

committed to achieving the U.S. government’s prior goal of reducing carbon dioxide emissions by 2025. 

Hawaii Governor David Ige 

Document ID: BOEM-2017-0050-51353 

The Hawaii Governor recommends the exclusion of the waters off Hawaii in the National Program. He 

states that there are no indigenous oil and gas resources and lacks an OCS. The governor notes that the 

state looks to its natural resources—wind, solar, geothermal, and the possibility of renewable energy 

resources from wind and ocean wave resources—to assist in achieving its goal of generating 100 percent 

of Hawaii’s energy in the electricity sector from renewable energy resources by the year 2045. 

Oregon Governor Kate Brown’s Office 

Document ID: BOEM-2017-0050-49816 

Oregon Governor Brown’s Energy Policy Advisor submitted comments on her behalf, stating that the 

state had supported the congressional moratorium on the west coast since 1990 and had a long history of 

opposing efforts to lease for oil and gas in Oregon OCS waters. The Energy Policy Advisor notes that 

state laws and policies prioritize long-term use and protection of renewable resources and that Oregon’s 

various ocean-related plans, including their CZM plan, are guided by such. The Energy Policy Advisor 

notes that in 2010 the state passed a law prohibiting oil and gas leasing in the Oregon Territorial Sea. 

Oregon is opposed to the inclusion of any Oregon OCS lands in the 2019–2024 National Program. 

Washington Departments of Ecology, Natural Resources, and Fish and Wildlife 

Document ID: BOEM-2017-0050-49524 

The agencies oppose the inclusion of areas adjacent to Washington in the Washington-Oregon Planning 

Area and noted significant concerns about the added risks and impacts on ocean and community resources 

that would result from oil and gas leasing and development in their offshore waters. The agencies stated 

that oil and gas leasing, exploration, and production on the OCS is inconsistent with Washington State’s 

laws, policies, and goals. Washington State law prohibits oil and gas exploration, production, and drilling 

in the state’s marine waters. Revised Code of Washington (RCW) 43.143.010 and RCW 90.58.160 

establishes state policies guiding ocean management, which are currently included as part of 

Washington’s federally approved CZM Program, including prioritizing ocean uses that do not adversely 

impact renewable resources over those that have adverse impacts on renewable resources, conserving 

fossil fuels, and protecting existing ocean uses and ocean resources from likely long-term significant 

adverse effects, and creates a framework for developing marine plans for Washington’s waters, including 

addressing potential for marine renewable energy (RCW 43.372). 

Summaries of Public Comments A-17 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

A.1.4 Gulf of Mexico Region1 

Alabama Governor Kay Ivey 

Document ID: BOEM-2017-0050-49698 

The governor states that the State of Alabama has a keen awareness of the importance of oil and gas 

production to the state’s economy and national security and has long supported a balanced and reasonable 

leasing program, contingent on all OCS activities adjacent to Alabama being carried out in compliance 

with state laws, rules, and regulations and consistent with its CZM program. The governor states that 

Alabama has long requested protection for live bottom habitats, pinnacle reefs, chemosynthetic 

communities, and other sensitive environments and noted that the state also has long opposed leasing 

within 15 miles off Baldwin County to minimize visual and other impacts. The governor urges that all 

unleased areas of the OCS be included in the DPP. The governor emphasizes that revenues should be 

shared with adjacent states and supports the existing sharing, but believes it should be expanded and 

enhanced. 

Florida Department of Environmental Protection, Department of State, Florida Fish and Wildlife 

Conservation Commission, Florida Geological Survey, and Treasure Coast Regional Planning 

Council 

Document ID: BOEM-2017-0050-49640 

The Florida Department of Environmental Protection (FDEP) coordinated a review by several state 

agencies. The Department states that Florida’s coastal and offshore areas have high environmental and 

economic value not only for Florida, but also for the Nation. In addition, FDEP notes that several areas 

offshore Florida are considered an essential component for developing and sustaining military readiness 

and that the state remains concerned about the effects of OCS oil and gas activities on marine and coastal 

environments and the sensitive biological resources and critical habitats associated with them as well as 

the military activities critical to the Nation’s security. FDEP states that as BOEM proceeds with the 

development of a proposed program for oil and gas activities, the long-term protection of Florida’s 

sensitive coastal and marine resources should be of paramount concern. Enclosed were comments from 

the Florida Department of State, Florida Fish and Wildlife Conservation Commission, Florida Geological 

Survey, and Treasure Coast Regional Planning Council as part of the review. 

Louisiana Department of Natural Resources 

Document ID: BOEM-2017-0050-19783 

The Louisiana DNR, Office of Coastal Management supports exploration and development throughout 

OCS waters and stated that domestic expansion will present positive opportunities for American workers 

and business owners, while benefiting the entire Nation. The Office notes that the coastal area of 

Louisiana continues to suffer adverse cumulative and secondary impacts from these activities and that 

Louisiana has endured wetland losses at an alarming rate throughout the 50-year history of BOEM lease 

sales in the Gulf of Mexico (GOM) and continues to do so today. The Office does not believe Louisiana 

has received adequate habitat mitigation commensurate with these impacts and stated that the upcoming 

OCS leasing program presents a fresh opportunity to rectify the situation, and develop a protocol for 

addressing these impacts. The Office states that at this early stage in lease sale planning, it is appropriate 

1 Gulf of Mexico section includes comments from Florida that address both Atlantic and Gulf of Mexico. 

Summaries of Public Comments A-18 January 2018 
 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

for BOEM to embrace its role as steward of these Federal resources and address the secondary and 

cumulative impacts resulting from these OCS activities. 

Texas Railroad Commission, Chair 

Document ID: BOEM-2017-0050-49538 

The Chair of the Texas Railroad Commission, the agency with oversight of the Texas energy industry, 

conveys strong support for a program that includes all 26 planning areas and stated that excluding areas at 

the outset and in the absence of critical environmental analysis would be premature and potentially 

harmful to efforts to enhance American energy security. 

Texas Railroad Commissioner Christian 

Document ID: BOEM-2017-0050-49523 

The Commissioner of the Texas Railroad Commission conveys his staunch support for developing a new 

leasing program that includes all 26 OCS planning areas in the development of the DPP and stated that 

excluding regions from leasing without critical environmental analysis would be premature and harm 

efforts to ensure American energy security. 

Texas Railroad Commissioner Sitton 

Document ID: BOEM-2017-0050-49602 

The Commissioner of the Texas Railroad Commission supports a robust leasing program that includes all 

26 planning areas. 

A.1.5 Atlantic Region 

Connecticut Department of Energy and Environmental Protection 

Document ID: BOEM-2017-0050-49730 

The Connecticut Department of Energy and Environmental Protection comments that the state has 

consistently opposed the inclusion of the North Atlantic in a National Program. The Department states 

that if the North and Mid-Atlantic were to be included, the state’s laws, goals, and policies, as contained 

in its Coastal Zone Management (CZM) Act, must be addressed, which include a list of resources and 

uses typifying the coastal environment and a description of the adverse impacts on such resources and 

uses that could result from development activities. The Department notes that the state supports the 

development of alternative energy sources and actions aimed at conserving fossil fuels. 

Delaware Governor John Carney 

Document ID: BOEM-2017-0050-49493 

The State of Delaware is opposed to any future leasing, exploration, development, or production of oil 

and gas in the Atlantic Ocean. The governor states that reinitiating program development at this time is 

an inefficient use of government resources and merely politicizes what should be a data-driven and public 

process. The governor states that the marine habitats and the species that rely on them are nationally 

shared resources that do not adhere to federally designated offshore boundaries and that the canyons that 

extend from off Massachusetts to North Carolina are of particular importance. 

Delaware Department of Natural Resources and Environmental Control 

Document ID: BOEM-2017-0050-49496 

The Delaware DNR and Environmental Control states that it has been on record for almost a decade 

opposing offshore oil and gas exploration in the Mid-Atlantic region and that these comments reiterate 

Summaries of Public Comments A-19 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

concerns previously expressed by the Department during the preparation of the 2017–2022 Program, and 

outline pertinent regulatory requirements of the State of Delaware. The Department states that the current 

program will meet national energy needs; therefore, there is no legitimate economic justification for 

exploration in the Mid-Atlantic. The Department states that the state’s 1971 Coastal Zone Act, adopted 

into the state’s CZM program in 1979, requires Federal applicants to be wholly consistent with the state’s 

Coastal Zone Act. The Department states that promotion of alternative energy development in the 

MidAtlantic is of utmost importance to the citizens of Delaware and that the Department is adamantly 

opposed to oil and gas lease sales and exploration in the Atlantic OCS. 

Georgia Department of Natural Resources 

Document ID: BOEM-2017-0050-49659 

The Georgia DNR, on behalf of Governor Dial, states support for environmentally sound efforts to 

increase the domestic oil and gas reserves of the United States. The Department notes several issues that 

must be considered in any leasing program involving Georgia offshore waters including the impacts of oil 

and gas exploration and production on: 1) the physical environment; 2) the biological environment; and 

3) the socioeconomic environment of the state. The Department includes a more detailed discussion of 

these categories of impact in the Technical Addendum to the letter. In summary, the state supports the 

preparation of an OCS oil and gas leasing program provided that all relevant environmental and societal 

issues are fully addressed. The Department states that given the current need for greater energy security 

in the United States, the state supports an effective state and Federal partnership that explores options for 

new energy resources. 

Maryland Attorney General 

Document ID: BOEM-2017-0050-49575 

The Attorney General of Maryland writes to express strong opposition to any efforts to open up the MidAtlantic OCS lease area to oil and gas exploration and drilling, as it would cause unacceptable and 

significant environmental and economic effects on the State’s natural resources and coastal communities. 

In March 2015, the commenter voiced opposition to the proposed Atlantic lease sale in the 

2017–2022 DPP. After an extensive public process, BOEM decided to remove the Mid-Atlantic area 

from the current Program and acknowledged that drilling off the Atlantic coast is ill-advised due to 

market dynamics, strong local opposition, and conflicts with competing commercial and military ocean 

uses. Those concerns remain unchanged today. Drilling off the Mid-Atlantic coast continues to be 

ill-advised and ignores the strong opposition from the local communities that would be most impacted by 

oil and gas drilling. Accordingly, the current Program should remain in place through 2022 and any new 

Program should exclude the Mid-Atlantic OCS for oil and gas exploration and drilling activities. 

Maryland Department of Natural Resources 

Document ID: BOEM-2017-0050-49494 

The Maryland DNR opposes opening up the Mid-Atlantic OCS lease area for oil and gas exploration and 

development activities as part of the 2019–2024 National OCS Oil and Gas Leasing Program, stating that 

from both an economic and environmental perspective, Governor Hogan’s administration is opposed to 

offshore oil and gas drilling off our coast and has serious concerns about seismic surveys and testing in 

the Atlantic Ocean. The Department stated that over the past several years, Maryland has worked 

together with Mid-Atlantic local, state, Federal, and tribal partners, as well as citizens, to begin charting a 

future for the ocean that ensures a healthy ocean ecosystem and supports sustainable ocean uses. The 

Summaries of Public Comments A-20 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Department stated that Maryland is concerned about the threat of oil spills and their direct and indirect 

effects on coastal and bay ecosystems and economies and that these risks raise significant questions about 

the cost and benefit of pursuing oil and gas leasing in sensitive coastal environments. The Department 

urges the exclusion of the Atlantic OCS lease areas from the 2019-2024 planning program. 

Massachusetts Governor Charles Baker 

Document ID: BOEM-2017-0050-49771 

The governor states that the Commonwealth does not support inclusion of areas of the North Atlantic 

adjacent to or affecting Massachusetts and stated that neither exploration nor leasing has been justified in 

the North Atlantic for more than three decades and that model still holds true. The governor supports 

wind energy in the OCS off Massachusetts and BOEM’s coordination of such efforts. 

Massachusetts Attorney General 

Document ID: BOEM-2017-0050-49550 

Because of the risks it poses to the Massachusetts economy and its coastal ecosystem, the 

Commonwealth’s Attorney General strongly opposes opening up any portion of the Atlantic—or any 

other new ocean areas—to oil and gas leasing. The Attorney General states that our country does not 

require expanded offshore fossil fuel extraction to meet our future energy needs, nor can we afford the 

increased GHG emissions that would result from such development. The Attorney General states that sea 

level rise from climate change already threatens our coastal communities and urges BOEM to withdraw 

its notice, discontinue preparation of a new program, and maintain the recently finalized program, which 

forecloses leasing in any new areas of the Gulf and Arctic Ocean, and in the entire Atlantic and Pacific 

OCS. 

Massachusetts Energy and Environmental Affairs, Coastal Zone Management Office 

Document ID: BOEM-2017-0050-49506 

The Commonwealth’s Coastal Zone Management Office reiterates the position of the governor and 

attached the governor’s comment letter opposing oil and gas leasing in the North Atlantic. 

New York Attorney General, Environmental Protection Bureau 

Document ID: BOEM-2017-0050-49556 

The Environmental Protection Bureau submitted comments on behalf of the state’s Attorney General, 

focusing on the legal obligations of BOEM to address the potential climate change implications of 

development of a new National Program. The Bureau believes that in preparing a new Program, the 

requirements of Section 18 of the OCS Lands Act dictate full consideration of whether expanded oil and 

gas on the OCS would interfere with the U.S. ability to mitigate the substantial adverse societal impacts 

of climate change. 

New York Departments of State and Environmental Conservation and Energy Research and 

Development Authority 

Document ID: BOEM-2017-0050-49625 

The New York Departments of State and Environmental Conservation and the Energy Research and 

Development Authority cite the state’s energy plan developed under the direction of Governor Andrew 

Cuomo that seeks to grow the state’s clean energy industry, reduce emissions that contribute to the 

frequency of extreme weather events, and manage its coastal waters in a manner to mitigate potential 

harm to communities and environment. The departments state that any renewed consideration of oil and 

Summaries of Public Comments A-21 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

gas development off the coast of New York would disrupt existing plans to develop clean offshore wind 

generation and harm the state’s continued efforts to protect and preserve the quality of life for New 

Yorkers and that activities associated with any OCS oil and gas exploration and production offshore 

would have reasonably foreseeable effects on New York’s coastal uses and natural resources that go 

beyond discrete siting concerns and threaten New York’s coastal economy. The departments state that 

these effects pertain to enforceable coastal policies of New York’s federally approved Coastal 

Management Program and would be subject to Federal consistency review and that the review would 

include State Coastal Policy 29, which specifically addresses the diversity of OCS uses and resources 

important to New York State’s coastal and statewide economy. The departments state that of particular 

concern are potential effects that oil and gas activities could have on the current and future conditions of 

the state’s energy economy and ocean environment, including the potential for oil spills and 

contamination. 

New Jersey Department of Environmental Protection 

Document ID: BOEM-2017-0050-49674 

The Department of Environmental Protection, on behalf of Governor Chris Christie, strongly opposes any 

waters off its coastline (North and Mid-Atlantic) being considered for inclusion in this leasing program 

and stated that New Jersey has consistently and steadfastly opposed any industrialization of its coast, 

including the exploration and development of offshore oil and natural gas resources, nor into any portion 

of the Atlantic Ocean that could negatively impact New Jersey’s precious natural resources or vibrant 

coastal communities. The Department states that the risk of adverse impacts on its marine waters and the 

species that depend on them is unacceptable. 

North Carolina Governor Roy Cooper 

Document ID: BOEM-2017-0050-49606 

The governor states that drilling threatens the state’s coastal economy and environment therefore requests 

that the current leasing program be maintained with the prohibition of oil and gas leasing off the North 

Carolina coast. The governor included a comment letter from the Secretary of Environmental Quality that 

reiterated the state’s opposition and presented a summary of the unique geographical and marine 

environments and the socioeconomic, legal, and policy frameworks that must be considered in the 

evaluation of including the waters of the state’s coast. In the attached letter from the Department of 

Environmental Quality, it was noted that the state has had a CZM program since 1974. Energy policies 

first adopted in 1979 were codified as law in 2010 and approved as enforceable policies by the National 

Oceanic and Atmospheric Administration (NOAA) in 2016. These include lists of the types of nearshore 

and offshore sensitive areas to be avoided, required mitigation where impacts cannot be avoided, and 

restoration of sites when facilities are abandoned. 

North Carolina Lieutenant Governor Dan Forest 

Document ID: BOEM-2017-0050-00304 

As Lieutenant (Lt.) Governor and as chair of the North Carolina Energy Policy Council, the commenter 

writes in support of including the Federal lands off the coast of North Carolina for oil and natural gas 

exploration. The Lt. Governor states that the North Carolina Energy Policy Council, which is the central 

energy policy planning body of the state, recommended in its last comprehensive report that “harnessing 

offshore energy reserves in an environmentally safe and responsible manner will lead to greater economic 

prosperity for North Carolina.” The Lt. Governor encourages legislative efforts to promote revenue 

Summaries of Public Comments A-22 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

sharing with coastal energy states and stated that to bring offshore energy development to North Carolina, 

the state will need to develop onshore infrastructure, ports and inlets, and regulatory programs as well as 

obtain local support. The Lt. Governor states that without revenue sharing, many coastal residents feel 

that they are being asked to bear all the costs and risks without reaping any of the rewards. The 

Lt. Governor states that offshore production could bring economic benefits and thousands of jobs to the 

state as well as the Nation’s economy and that this would strengthen the Nation’s economic security as 

well as energy independence. 

Virginia Governor Terence McAuliffe 

Document ID: BOEM-2017-0050-49554 

The governor states his understanding that BOEM is considering for inclusion in the new National OCS 

Program all unleased areas off the U.S. OCS, including unleased areas off the coast of Virginia. The 

governor states that, as was made clear in the state’s comments submitted during the process to develop 

the 2017–2022 Program, a primary concern that must be satisfied for Virginia to be included in the 

leasing area is a revenue-sharing agreement between participating Atlantic coast states and the Federal 

government. The governor states that as the parties are no closer to resolving this issue; Virginia requests 

that the Commonwealth not be included in the new Program. 

Virginia Lieutenant Governor Ralph Northam 

Document ID: BOEM-2017-0050-49502 

The Lt. Governor’s Chief of Staff stated that the Lt. Governor’s position has not changed from a 

February 26, 2016, letter submitted to BOEM in which the Lt. Governor asked that Virginia be excluded 

from the National OCS Program. The Lt. Governor cites effects of climate change, military and NASA 

assets, tourism, a growing seafood industry, and the uncertainty over royalty disbursements. 

A.2 LOCAL GOVERNMENTS 

A.2.1 Alaska Region 

North Slope Borough 

Document ID: BOEM-2017-0050-49652 

The North Slope Borough (NSB) states that it has been a partner with the oil and gas industry, the State of 

Alaska, and the Federal government since its incorporation in 1972. The NSB states that responsible 

natural resource development is essential to the vitality of the North Slope and that, to date, resource 

development is a major economic generator for the region. The NSB states that resource development 

provides direct benefits, such as jobs and dividends distributed through local and regional Alaska Native 

corporations, and moreover, the NSB’s taxation of oil and gas infrastructure provides the bulk of its 

revenues, which are used to fund its facilities, operations, and services that benefit all residents of the 

North Slope. The NSB states that if exploration, development, and production do occur on the OCS, the 

Federal government and industry must implement comprehensive measures to ensure that these activities 

will be conducted in a safe and responsible manner, which include but are not limited to: (1) continuing to 

enhance and realistically test oil spill prevention and response capabilities under the full range of 

foreseeable Arctic conditions; (2) restricting the number of lease sales to a manageable level and 

requiring consultation with impacted communities; (3) excluding or deferring from lease sales areas that 

are critical to subsistence hunting, and requiring offshore leaseholders and operators to enter into Conflict 

Avoidance Agreements with the Alaska Eskimo Whaling Commission and other marine mammal user 

Summaries of Public Comments A-23 January 2018 
 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

groups; (4) funding and conducting scientific research and monitoring, with appropriate peer-review, of 

the potential effects of industrial activity on the Arctic marine ecosystem; (5) requiring lease holders to 

conduct comprehensive, pre-activity, site-specific research in areas of proposed operations; (6) supporting 

and implementing a revenue-sharing mechanism and job training activities to help mitigate the impacts of 

development on affected communities; and (7) requiring the transportation of OCS-produced oil via 

subsea pipelines to shore-based facilities whenever possible. 

A.2.2 Pacific Region 

California, City of San Luis Obispo 

Document ID: BOEM-2017-0050-51355 

The City of San Luis Obispo opposes any oil and gas activity off its coast. 

California, City of Santa Barbara 

Document ID: BOEM-2017-0050-49718 

The City of Santa Barbara passed Resolution 17-084 on July 25, 2017, calling for “support, in state and 

Federal waters in the Pacific Ocean along the United States: 1) a ban on new drilling, tracking, and related 

techniques; 2) a phase-out of all oil and gas extraction; and 3) a framework for responsible renewable 

energy development.” 

California, Santa Barbara County 

Document ID: BOEM-2017-0050-24128 

The County of Santa Barbara opposes to any new oil and gas lease sales in the Pacific OCS. 

California, Santa Barbara Air Pollution Board 

Document ID: BOEM-2017-0050-49518 

The Santa Barbara Air Pollution Board is concerned about the impacts on air quality from any new 

leasing that could result from increased construction, drilling, and transportation of crude oil to market. 

The Board emphasizes that these concerns need to be addressed in the EIS and that any activity has 

coastal zone consistency. 

California, Ventura County 

Document ID: BOEM-2017-0050-08622 

The Ventura County Board of Supervisors voted to express its strongest opposition to any new oil and gas 

lease sales in the Pacific OCS and stated that new offshore oil and gas exploration is incompatible with 

Ventura County’s thriving tourism and fishing economy, and that it is not consistent with the sustainable, 

green coastal economy the County is striving to develop. 

Washington, North Pacific Coast Marine Resources Committee 

Document ID: BOEM-2017-0050-49544 

The North Pacific Coast Marine Resources Committee, an advisory committee primarily to some counties 

in Washington, requests that information from the state Marine Spatial Plan (currently a draft) be 

represented and documented in the DPP, including any anticipated environmental and economic 

consequences of oil and gas development. The Committee does not feel that the exploration and 

development of oil and gas resources offshore of the Olympic Peninsula can be conducted in a safe and 

environmentally sound manner. 

Summaries of Public Comments A-24 January 2018 
 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

A.2.3 Gulf of Mexico Region2 

Louisiana, Greater Lafourche Port Commission 

Document ID: BOEM-2017-0050-47967 

As the manager of the Nation’s busiest energy port servicing the oil and gas industry in the GOM, the 

Commission states that the benefits to the Nation of continued and expanded oil and gas exploration and 

production in the GOM is absolutely essential to not only the economic future, but environmental 

sustainability in the face of climate change. The Commission states that while the Port is grateful to be 

able to service the 6 percent of the Nation’s OCS areas available for development, the other 94 percent of 

OCS areas off-limits to offshore oil and gas development deserve to have the opportunity to decide for 

themselves if they wish to capitalize on opportunities to create American jobs, grow America’s economy, 

improve America’s national security, and ensure America’s energy dominance well into the future. 

Louisiana, Madison Parish Port Commission 

Document ID: BOEM-2017-0050-49764 

The Madison Parish Port Commission states that all 26 planning areas should be included in the DPP, that 

access in the GOM should be expanded, and that additional energy-related revenue sharing would go a 

long way to helping fund projects and programs vital to Louisiana. 

Florida, City of Coconut Creek 

Document ID: BOEM-2017-0050-49499 

The City of Coconut Creek in southeastern Florida is opposed to expansion of offshore drilling in the 

Atlantic Ocean. 

Florida, Martin County 

Document ID: BOEM-2017-0050-08702 

Martin County in southeastern Florida opposes the expansion of offshore drilling in the Atlantic Ocean. 

Florida, Miami-Dade County 

Document ID: BOEM-2017-0050-49747 

Miami-Dade County passed Resolution R-651-17 on June 20, 2017, opposing offshore exploration and 

drilling in the Eastern GOM and Atlantic region and opposes the issuance of permits enabling the use of 

airguns for seismic. 

Florida, Monroe County 

Document ID: BOEM-2017-0050-49539 

Monroe County, including the Florida Keys and located between the Atlantic and GOM, strongly 

supports the extension of the moratorium on drilling in the Eastern GOM beyond 2022 and remains 

strongly opposed to any expansion of drilling in the GOM, the Straits of Florida, or off the Atlantic Coast 

of Florida. The commenter states that Monroe County has a longstanding opposition to offshore drilling 

and has passed several resolutions on the issue dating back to 1987, and as recently as April 2017. 

2 Gulf of Mexico section includes Florida local governments, both Gulf and Atlantic coasts. 

Summaries of Public Comments A-25 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Florida, Pinellas County 

Document ID: BOEM-2017-0050-49576 

Pinellas County, a peninsula on the central Gulf coast of Florida, states opposition to offshore drilling in 

the Eastern GOM and supports making the current moratorium permanent. 

Florida, St. Lucie County 

Document ID: BOEM-2017-0050-49605 

St. Lucie County on the Atlantic coast of Florida states opposition to drilling off the coast of Florida. 

A.2.4 Atlantic Region 

New Jersey, Borough of Avalon 

Document ID: BOEM-2017-0050-18373 

The Borough of Avalon states opposition to all offshore oil and gas exploration off the coast of New 

Jersey, including seismic airgun blasting to search for oil and gas and offshore deposits. 

New Jersey, Borough of Stone Harbor 

Document ID: BOEM-2017-0050-49790 

The Borough of Stone Harbor states opposition to all offshore oil and gas exploration off the coast of 

New Jersey, including seismic airgun blasting to search for oil and gas and offshore deposits. 

New Jersey, Cape May County 

Document ID: BOEM-2017-0050-49791 

By Resolutions 113-15 and 675-16, the Cape May County Board of Chosen Freeholders states that they 

took action to oppose offshore drilling and seismic air gun testing in the Atlantic Ocean. The County of 

Cape May states that they remain convinced today, as it was at the adoption of these resolutions, that 

offshore oil and gas development is an unreasonable threat to its citizens, environment, and economy. 

New York, Brookhaven Long Island 

Document ID: BOEM-2017-0050-49684 

A Supervisor from the Town of Brookhaven, Long Island, expresses his strong opposition to a proposed 

leasing program for offshore drilling in the Atlantic and Arctic Oceans. The Supervisor asks BOEM to 

oppose any effort to reopen the Atlantic or Arctic Oceans for offshore drilling and states that opening the 

Atlantic to offshore drilling would put New York’s coastal communities’ jobs and ecosystems in danger. 

North Carolina, Bald Head Island 

Document ID: BOEM-2017-0050-49638 

Bald Head Island comments that the current program as finalized in January 2017 did not include any 

lease sales in the Mid-Atlantic or South Atlantic planning areas. The commenter states that as a 

community that could be directly and dramatically impacted by oil and gas exploration and leasing in 

proximity to its beaches, marshes, wildlife and other natural resources, Bald Head Island opposes this 

untimely reopening of the process. The commenter states that oil and gas development near Bald Head 

Island is inconsistent with the history, economy, culture, and environment of this special place. The 

commenter provides details about its location, environment, and areas of particular concern, and 

addressed the questions raised in the RFI. The commenter also attached a 2015 Resolution opposing 

seismic testing and offshore drilling. 

Summaries of Public Comments A-26 January 2018 
 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

North Carolina, Caswell Beach 

Document ID: BOEM-2017-0050-49541 

Caswell Beach, located on a southeastern North Carolina barrier island, asks BOEM to investigate and to 

take into consideration possible adverse effects related to oil and gas drilling activities, including seismic 

testing, near the Atlantic outfall of the Cape Fear River and the local economy due to the National OCS 

Program 2019–2024. 

North Carolina, Duck 

Document ID: BOEM-2017-0050-46728 

The Town of Duck submits a 2014 Resolution in opposition to offshore fracking and drilling. 

North Carolina, Kill Devil Hills 

Document ID: BOEM-2017-0050-49553 

The Mayor of Kill Devil Hills submits the letter sent to the governor expressing consistent opposition to 

offshore oil and gas exploration. The submission included earlier actions expressing the opposition. 

North Carolina, Southport, Mayor 

Document ID: BOEM-2017-0050-49571 

The Mayor of Southport expresses opposition to proposed 2019–2024 OCS oil and natural gas leasing 

program, to allow seismic surveying and offshore exploration and drilling off the North Carolina Coast. 

The commenter includes two earlier passed resolutions in opposition to seismic surveying and offshore 

oil and gas exploration. 

North Carolina, Southport, Alderman 

Document ID: BOEM-2017-0050-49566 

The Alderman expresses opposition to oil and gas leasing off the coast of North Carolina, including 

related activities such as seismic testing. The commenter states that the current program should not be 

modified after all planning areas in the Atlantic Ocean were removed from the 2017–2022 Program. The 

commenter states that the city passed a resolution in opposition to seismic testing and offshore oil and gas 

exploration. 

North Carolina, Sunset Beach 

Document ID: BOEM-2017-0050-49492 

Sunset Beach submits a June 5, 2017, Resolution in opposition to exploration and production of 

petroleum products off the coast of North Carolina. 

South Carolina, Georgetown County 

Document ID: BOEM-2017-0050-49627 

The County of Georgetown submits a July 25, 2017, Resolution in opposition to seismic testing and 

offshore drilling activity off the South Carolina coast. 

South Carolina, Hilton Head Island 

Document ID: BOEM-2017-0050-49811 

The Town of Hilton Head Island opposes reconsideration of the geophysical permits using seismic 

airguns in the Atlantic. The Town states concern about the seismic testing itself and sees it as the first 

step toward oil drilling off the coast of South Carolina. 

Summaries of Public Comments A-27 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

South Carolina, Horry County 

Document ID: BOEM-2017-0050-51350 

The Horry County Council expresses its opposition to offshore exploration drilling along the South 

Carolina coast and in the adjacent Atlantic Ocean. The county also opposes seismic airgun blasting in the 

Atlantic Ocean. The County Council believes that that the slight and speculative benefit of oil and gas 

exploration and drilling, which would likely accrue to the global energy market, is not worth the risk of 

even a single incident that would cripple the local and state-wide economy. 

South Carolina, Seabrook Island 

Document ID: BOEM-2017-0050-49812 

The Town of Seabrook Island considers the potential adverse environmental impacts associated with 

constructing and operating offshore oil and gas industry and its supporting infrastructure would far 

outweigh any potential economic benefits to the State of South Carolina and its coastal communities. 

South Carolina, Sullivan’s Island 

Document ID: BOEM-2017-0050-49807 

The Town of Sullivan’s Island submits a 2015 Resolution in opposition to seismic testing and offshore 

drilling activities. 

Virginia, Virginia Beach 

Document ID: BOEM-2017-0050-49507 

The City of Virginia Beach submits a June 20, 2017, Resolution in opposition to offshore oil and gas 

exploration, including seismic testing. 

A.3 PUBLIC INTEREST GROUPS 

Alaska Eskimo Whaling Commission, Jessica Lefevre 

Document ID: BOEM-2017-0050-49565 

The Alaska Eskimo Whaling Commissions (AEWC) expresses support for continued leasing in the Arctic 

OCS because of the importance offshore activities have to their local economy. The commenter states 

cooperation between BOEM, offshore operators, and their organization is crucial to their operations. The 

commenter states their whalers negotiate with offshore developers annually to determine the best way for 

their operations to coexist. Therefore, the commenter requests BOEM sponsor discussions among AEWC 

representatives, agency personnel, and offshore operators to develop a plan for providing long-term 

support for joint work to balance the subsistence needs of northern Alaskan communities and 

development goals for the Arctic OCS. 

Alaska Marine Conservation Council, Kelly Harrell 

Document ID: BOEM-2017-0050-24940 

The commenter expresses opposition to offshore drilling in Alaska and supports the existing withdrawal 

of the North Aleutian Basin. Bristol Bay’s economy strongly relies on commercial and recreational 

fishing, and the commenter argues that the ecological, cultural, and economic resources in the Bristol Bay 

are too valuable to risk with development of offshore drilling. 

Summaries of Public Comments A-28 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Albermarle Garden Club, Carter 

Document ID: BOEM-2017-0050-49834 

The commenter expresses opposition to offshore oil and gas and seismic testing in the Atlantic. The 

commenter argues that oil and gas drilling risks jobs in commercial fishing and shellfish industries, 

tourism, and the health of both wildlife and humans. The commenter further argues seismic testing is 

potentially deadly too aquatic life, and these harms are not worth the risk. 

Americans for Prosperity, Jeremy Price 

Document ID: BOEM-2017-0050-10125 

The commenter expresses support for the inclusion of all 26 planning areas in the development of the 

DPP for the 2019–2024 offshore oil and gas leasing program. The commenter supports the new program 

reconsidering the Alaskan Arctic after its removal from the 2017–2022 Program. The commenter argues 

that oil and gas development of the Chukchi and Beaufort seas would result in job creation and both state 

and Federal revenue, as well as increase the longevity of the TAPS. 

Association to Preserve Cape Cod, Don Keeran 

Document ID: BOEM-2017-0050-49501 

The commenter expresses opposition to any changes to the current program that would open up leasing in 

the outer continental shelf of the Atlantic and Arctic Oceans. The commenter argues that sensitive coastal 

ecosystems on the Atlantic, such as Cape Cod, would be devastated by an oil spill anywhere along the 

coast. The commenter requests the moratorium on oil and gas drilling in the Atlantic and Arctic Oceans 

be preserved and more investments in renewable energy sources be made. 

Atlantic States Marine Fisheries Commission, Lisa Havel 

Document ID: BOEM-2017-0050-49560 

The commenter expresses opposition to the inclusion of the Atlantic OCS from Maine to Florida from the 

2019–2024 Program. The commenter states the commercial and recreational fishing industries supported 

nearly half a million jobs and over $20 billion in revenue for the Atlantic coast in 2015 alone. The 

commenter argues it is unknown how seismic surveys would impact marine species, but these industries 

are far too valuable to risk. 

Audubon California, Michael Lynes 

Document ID: BOEM-2017-0050-49533 

The commenter expresses opposition to the inclusion of the Pacific OCS and California planning areas 

from the 2019–2024 Program. The commenter argues that these marine ecosystems are too sensitive and 

valuable to put in harm’s way for the sake of oil and gas extraction. The commenter further argues that 

oil and gas activity goes against the interests of the states along the Pacific Coast, whose economies all 

rely on coastal industries such as fishing and tourism. 

Camden Creek HOA, Rick Hoffman 

Document ID: BOEM-2017-0050-10124 

The commenter expresses opposition to offshore oil and gas drilling in the Atlantic. The commenter 

argues this activity is too risky and could devastate the economy and environment of South Carolina. 

Summaries of Public Comments A-29 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Cars Are Basic, Scott Wenz 

Document ID: BOEM-2017-0050-49620 

The commenter expresses support for oil and gas development on and offshore in California. The 

commenter argues that developing oil and gas reserves on the Pacific coast would serve the interests of 

the citizens of both the state and the United States, and this development will help the United States 

become more economically and energy secure. 

Center for a Sustainable Coast, David Kyler 

Document ID: BOEM-2017-0050-08527 

The commenter expresses opposition to development of a new OCS program that would open any 

additional planning areas to oil and gas leasing. The commenter argues that the economic benefits would 

be short-lived and the activity is not justified by domestic energy need, and that these needs could be met 

with more sustainable forms of energy. The commenter further argues that a potential oil spill would 

devastate coastal communities, tourism and fishing industries, as well marine and aquatic ecosystems. 

Center for Biological Diversity, Earthjustice, Gulf Restoration Network, Sierra Club, 

Kristen Monsell 

Document ID: BOEM-2017-0050-49675 

The commenters express opposition to the expansion of oil and gas development in the Atlantic, Pacific, 

GOM, and all waters offshore Alaska. The commenters state their concern with expanding oil and gas 

development and argue that the United States should be transitioning to renewable and clean energy. The 

commenters argue expansion into areas already protected by a president violates Federal law. The 

commenters further argue that BOEM should further analyze the risks and impact of offshore oil and gas 

development on marine ecosystem, surrounding communities, and climate change. 

Center for Regulatory Effectiveness, Scott Slaughter 

Document ID: BOEM-2017-0050-49564 

The commenter expresses support for expanding oil and gas exploration in the Atlantic. The commenter 

also supports the proposed 500-meter exclusion zone, as it has shown no evidence of environmental harm 

in the GOM. The commenter argues that Passive Acoustic Monitoring should be used for exploration, 

but that the proposed acoustic guidance is flawed and should not be followed. 

Cetacean Society International, William Rossiter 

Document ID: BOEM-2017-0050-9651 

The commenter expresses opposition to including the Atlantic Planning area in the new 

2019–2024 leasing program. The commenter argues there should be no reason to reconsider this area 

other than Administrative pressure. The commenter further argues that seismic testing and development 

in this area would directly threaten some endangered species, such as the north Atlantic right whale, and 

there are a number of laws including the Endangered Species Act and the National Environmental Policy 

Act (NEPA) that exist to protect these species from harm. The commenter argues that without seismic 

surveys and with these protective acts in place, it will be difficult to find companies that will want to lease 

these areas. 

Summaries of Public Comments A-30 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Chesapeake Bay Foundation, Chris Moore 

Document ID: BOEM-2017-0050-49532 

The commenter expresses opposition to oil and gas drilling in the Atlantic OCS. The commenter argues 

oil and gas drilling and exploration could lead to pollution that would derail current Chesapeake Bay 

restoration efforts. The commenter further explains oil and gas exploration could negatively impact 

fishing and tourism industries, causing millions of dollars in profit loss. The commenter states the 

Atlantic leases were removed after years of public and stakeholder input and should not be included in the 

2019–2024 Program. 

Clean Ocean Action, Cindy Zipf 

Document ID: BOEM-2017-0050-49635 

The commenter expresses opposition to oil and gas drilling in the Atlantic OCS and requests that the RFI 

be rescinded and the current 2017–2022 leasing program remain. The commenter expresses concern for 

the waters off the coast of New Jersey and New York and the potential risks offshore drilling poses to 

marine life diversity, tourism, recreational and commercial fishing, and property values. The commenter 

also argues that oil and gas drilling will further accelerate climate change and put the coasts at risk of sea 

level rise and sea surges. The commenter states that expanded oil and gas leasing will not make America 

energy-independent and will only benefit private companies. 

Coastal Carolina Riverwatch, Larry Baldwin and James Corner 

Document ID: BOEM-2017-0050-48075 

The commenter expresses opposition to the inclusion of the Atlantic OCS in the 2019–2024 leasing 

program. The commenter argues that oil and gas leasing in the Atlantic would be detrimental to the 

coast’s marine life, the U.S. military, fishing and tourism industries, and the populations inhabiting these 

states. This planning area was removed from the 2017–2022 leasing program after two years of 

stakeholder input and widespread opposition. The commenter further argues the oil and gas reserves 

contain a relatively small amount of oil, and that any activity would not be worth the risks it poses to the 

coast. 

Coastal Coordination Program of the Ocean Foundation, Richard Charter 

Document ID: BOEM-2017-0050-24262 

The commenter expresses opposition to development of a new program, notably any new OCS leases in 

Alaskan waters. The commenter argues that inclusion of the Arctic Ocean ignores the ecological 

significance and environmental sensitivity of the region, as well as the lack of response capability and 

infrastructure in the event of an oil spill. The commenter also opposes reintroducing the Atlantic lease 

sales, arguing that the oil and gas development in the area would present military space-use conflicts and 

threaten the coastal economy and fisheries of the region. 

Consumer Energy Alliance, Dave Holt 

Document ID: BOEM-2017-0050-49593 

The commenter expresses support for expanding leasing opportunities in the Atlantic, GOM, and Arctic. 

The commenter argues that developing these leasing areas would create nearly one million jobs and 

generate billions of dollars in revenue for the states and Federal Government. The commenter further 

argues that oil and gas development is more environmentally safe than it has ever been, and development 

of these areas is critical to the energy and economic security of the United States. 

Summaries of Public Comments A-31 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Consumer Energy Alliance—Florida, Kevin Doyle 

Document ID: BOEM-2017-0050-51114 

The commenter expresses support for the development of a new leasing program and urges inclusion of 

all 26 planning areas in the DPP. The commenter states that excluding regions under consideration at the 

beginning of the process without critical environmental analysis would be premature and hurt American 

energy security. The commenter argues that offshore resource development provides significant 

economic impact for Florida, citing the revenue and jobs created by offshore resource development in the 

GOM. 

Earthjustice, Erik Grafe 

Document ID: BOEM-2017-0050-49670 

The commenter requests that BOEM abandon the effort to modify the current 2017–2022 oil and gas 

leasing program. The commenter expresses concern for offshore drilling in the Arctic OCS and requests 

that the Chukchi Sea and Beaufort Sea planning areas be excluded from the program. The commenter 

states that the Artic region is warming more rapidly and offshore drilling is incompatible with attempts to 

limit climate change. The commenter further argues that the risks associated with an oil spill would be 

exacerbated by limited spill response capabilities. 

Edisto Island Community Association, Fred Palm 

Document ID: BOEM-2017-0050-49841 

The commenter expresses opposition to seismic testing off the mid- and south Atlantic Coasts, as well as 

offshore oil and gas exploration. The commenter argues that not only has the energy sector has not 

expressed demand for more oil, but that policy should be moving towards more renewable energy. The 

commenter also argues that industries that rely on a healthy coastal habitat, such as commercial fishing 

and tourism, are too valuable to risk with seismic testing or exploration. 

Energy Institute of Alabama, Blake Hardwich 

Document ID: BOEM-2017-0050-19796 

The commenter expresses support for the expansion of offshore oil and gas leasing proposed in the 

2019-2024 Program. The commenter argues that expanding leasing will result in economic activity in the 

form of job creation and Federal and state revenue. The commenter further argues that utilizing all 

available offshore energy resources will help strengthen the energy and economic security of the United 

States. 

Environmental Defense Center, at al., Kristen Hislop 

Document ID: BOEM-2017-0050-49579 

The commenter expresses opposition to the inclusion of the Pacific OCS region from the National 

program and requests that it be excluded from the program. The commenter states that this region 

includes several National Marine Sanctuaries, National Parks and Monuments, and state marine protected 

areas, and development of these areas is not consistent with their protection. The commenter argues that 

oil and gas development would cause significant environmental harm to these already sensitive areas and 

exacerbate global warming. 

Summaries of Public Comments A-32 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Florida Wildlife Federation, Manley K. Fuller 

Document ID: BOEM-2017-0050-19718 

The commenter expresses opposition to any changes to the current 2017–2022 Program and opposes all 

new lease sales in the Atlantic, Pacific, and Arctic Oceans and Eastern GOM. The commenter argues that 

not only would the tourism economy of the east coast suffer in the event of an oil spill, but endangered 

marine mammals such as turtles and whales would be devastated. The commenter states that benefits of 

this activity are not significant enough to risk the economy and fragile ecosystems of the east coast. 

Friends of the Earth—US, Gary Hughes 

Document ID: BOEM-2017-0050-49587 

The commenter requests that the Pacific OCS be excluded from the 2019–2024 leasing program. The 

commenter states that offshore drilling is incompatible with California’s ecologically unique and 

protected coast and an oil spill would pose risks to endangered and threatened species. The commenter 

states that local economies, business and property owners, and the local fishing industry in California 

have already suffered economic loss due to spills. The commenter argues that oil spills are not the only 

risk posed by offshore drilling, but air and water pollution, and seismic instability as well. 

Georgia AgriBusiness Council, Bryan Tolar 

Document ID: BOEM-2017-0050-49529 

The commenter expresses support for the development of a new OCS leasing program, including the 

addition of all planning areas in the Atlantic OCS. The commenter argues that including the Atlantic 

Planning areas is crucial to maintain industry interest and would allow for more environmentally and 

economically effective exploration in the Atlantic OCS. The commenter further argues that development 

of this region could result in job creation and revenue for both the states and Federal Government. 

Georgia Conservancy, Charles McMillan 

Document ID: BOEM-2017-0050-49535 

The commenter expresses opposition to oil and gas leasing in the Atlantic Ocean off Georgia’s coast. The 

commenter argues that oil and gas leasing activity would disrupt the lives of residents, and damage 

critical ecosystems and the coastal economy. The commenter requests that BOEM move these leasing 

areas forward in the DPP and that they provide a detailed assessment of the ecological, hazardous, and 

economic impacts this activity would have on Georgia’s coastal environments. 

Gulf Economic Survival Team, Lori LeBlanc 

Document ID: BOEM-2017-0050-49559 

The commenter expresses support for developing a new leasing program that includes all 26 OCS 

planning areas. The commenter argues that the GOM should stand as the best example of the benefits oil 

and gas exploration can bring, citing the number of jobs created and the amount of revenue oil and gas 

production and brought the region. The commenter further argues that in order for the United States to 

become energy secure and energy dominant, the government must explore all available energy resources, 

including expanding leasing in the Gulf and other untapped leasing areas. 

Greenpeace USA, Timothy Donaghy 

Document ID: BOEM-2017-0050-49577 

The commenter requests that no lease sales be scheduled during the 2019–2024 proposed program and 

that BOEM conducts a comprehensive analysis of the climate change costs of existing or proposed 

Summaries of Public Comments A-33 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

offshore oil and gas extraction. The commenter states that oil and gas drilling has already caused serious 

damage to the GOM, and expanding lease sales in the Arctic, Atlantic, and Pacific OCS would place 

those communities at risk. The commenter argues that exploiting these resources in the Arctic is 

inconsistent with international efforts to limit global warming and would lock the United States into oil 

and gas infrastructure for many decades. 

Indivisible Northampton County, Joe Guest 

Document ID: BOEM-2017-0050-00048 

The commenter expresses opposition to expanding offshore oil and gas drilling. The commenter argues 

that oil and gas exploration is not critical to our Nation’s energy security or energy independence. The 

commenter further argues that oil and gas drilling could lead to a devastating oil spill. 

Jersey Shore Partnership, Margot Walsh 

Document ID: BOEM-2017-0050-49940 

The commenter expresses opposition to seismic testing in the Atlantic Ocean, especially off the coast of 

New Jersey. The commenter argues that there is little economic benefit to this proposal, and would cause 

harm to marine life, tourism, and the health and safety of the coastal residents. 

League of Women Voters of Carteret County, Carol Geer 

Document ID: BOEM-2017-0050-49498 

The commenter expresses opposition to oil and gas activity off the Atlantic coast. The commenter argues 

that oil and gas development off the coast of North Carolina would be detrimental to water quality and 

marine life. The commenter also argues that North Carolina and other Atlantic coast states have long 

opposed oil and gas activity off their coasts because of the potential impacts it could have on fishing and 

tourism industries. 

League of Women Voters of North Carolina, Margaret Salinger 

Document ID: BOEM-2017-0050-19236 

The commenter expresses opposition to coastal drilling and seismic testing in the Atlantic. The 

commenter argues that the environmental threat this activity poses for the North Carolina coast is not 

worth the small amount of oil and gas that could be generated. The commenter further argues that the 

country should be investing in more sustainable energy resources in the near future. 

League of Women Voters of the Lower Cape Fear, NC, Clarice Reber 

Document ID: BOEM-2017-0050-47906 

The commenter expresses opposition to offshore drilling in the Atlantic. The commenter argues that 

activity in the Atlantic threatens the fishing and tourism industries that are vital to the North Carolina 

economy. The commenter further argues that the benefits of OCS drilling were exaggerated by high oil 

prices, and the U.S. economy would benefit more from reducing its dependence on carbon-based fuels. 

League of Women Voters of New Jersey, Nancy Hedinger 

Document ID: BOEM-2017-0050-49634 

The commenter expresses opposition to the inclusion of the North and Mid-Atlantic Ocean in the 

2019-2024 DPP. The commenter states that offshore drilling will have a devastating effect on natural 

resources and water quality, as well as the tourism and recreational and commercial fishing industries in 

New Jersey. The commenter supports moving towards more renewable energy resources. 

Summaries of Public Comments A-34 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Lynnhaven River NOW, Karen Forget 

Document ID: BOEM-2017-0050-50158 

The commenter expresses opposition to seismic testing, as well as offshore oil and gas exploration and 

drilling off the Virginia coast in the Atlantic. The commenter explains that oil spills are difficult to clean, 

and clean coasts are critical to the economy of Virginia. The commenter argues that oil and gas are toxic 

to critical commercial fishing species such as blue crab and oysters, and loss of these populations would 

be detrimental to the fishing industry. The commenter also argues that this activity would negatively 

impact wetlands, which help reduce flooding and erosion. 

Los Angeles Waterkeeper, Jeannette Baudelaire 

Document ID: BOEM-2017-0050-49614 

The commenter expresses opposition to any expansion of oil and gas leasing and requests reconsideration 

of efforts to open the Atlantic, Arctic, Florida, and other Gulf Coast waters, as well as California’s 

coastline to expanded offshore oil and gas leasing. The commenter argues that offshore oil and gas 

leasing and development poses threats to coastal tourism and fishing industries, as well as ecologically 

damaging impacts from the release of wastewater, leaks, and spills. The commenter states that the current 

2017–2022 Program should be maintained. 

ManaSota-88, Inc., Glenn Compton 

Document ID: BOEM-2017-0050-08562 

The commenter expresses opposition to offshore oil and gas drilling off the coast of Florida and requests 

all areas off the Florida coast be excluded from the OCS program. The commenter argues that the EISs 

for the OCS have been inadequate. The commenter explains that commercial fishing, recreation, and 

tourism are vital to coastal economies and an oil spill would devastate these industries. The commenter 

argues oil and gas activity, including seismic exploration would significantly impact fragile ecosystems 

and their inhabitants, including seagrass, sea turtles, and deep sea benthic communities. 

Mid-Atlantic Fishery Management Council, Jessica Coakley 

Document ID: BOEM-2017-0050-

The commenter expresses concern about the potential impacts oil and gas drilling could have on sensitive 

marine environments in the Atlantic Ocean. The commenter argues that there is not a sufficient amount 

of information available to predict how oil and gas development would impact fish, marine mammals, and 

aquatic ecosystems. The commenter further argues that renewable energy could be developed in a 

manner that meets energy needs and has a minimal impact on marine habitats and fisheries. 

Mississippi Energy Institute, Patrick Sullivan 

Document ID: BOEM-2017-0050-08588 

The commenter expresses support for the development of a new leasing program and urged the inclusion 

of all 26 planning areas in the DPP. The commenter argues that offshore resource development provides 

significant economic impact for states, citing the revenue and jobs created in the GOM. The commenter 

also states that economic gains from oil and gas development would trickle through the economy of the 

entire country. 

Summaries of Public Comments A-35 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

National Audubon Society, Sarah Greenberger 

Document ID: BOEM-2017-0050-49503 

The commenter expresses opposition to expanded offshore oil and gas leasing and development in the 

Atlantic, Pacific, and Arctic Oceans, and the Eastern Gulf of Mexico, and urged the current program be 

maintained. The commenter argues expanding oil and gas exploration and development in sensitive areas 

such as the Arctic Ocean would put marine and coastal bird habitats at risk. The commenter further 

argues oil and gas development in the Arctic would be risky due to the climate and lack of infrastructure. 

The commenter states oil and gas development has never occurred in the Atlantic Ocean, and argued 

development would conflict with other ocean uses. 

National Parks Conservation Association 

Document ID: BOEM-2017-0050-49582 

The commenter expresses opposition to offshore oil and gas leasing and development in the Atlantic, 

Pacific, and Arctic oceans, and the Eastern GOM. The commenter expresses concern for coastal national 

parks in the Atlantic and Pacific oceans, and argues that offshore drilling poses threats such as costal 

industrialization, spills, and leaks that could impact the economic output of the parks and the jobs they 

support. The commenter also states that an oil spill could threaten marine wildlife and migratory birds. 

The commenter expresses concern for the weakening of safety rules, such as the 2016 Well Control Rule. 

Natural Resources Defense Council, Alexandra Adams 

Document ID: BOEM-2017-0050-49646 

The commenter expresses opposition to the development of a new National oil and gas leasing program 

and requests that the Atlantic, Pacific, and Arctic regions, as well as the North Aleutian Basin, Bristol 

Bay, Cook Inlet, and the GOM be excluded from the new program. The commenter argues that offshore 

drilling threatens the ecosystems, geological features, and ocean-based economies of the Atlantic Ocean, 

the unique marine wildlife and fishing and tourism industries of the Pacific Ocean, and the rich marine 

ecosystems and fishing industry of the Arctic. The commenter also argues that the Arctic region 

possesses limited oil spill response capabilities. 

New England Fishery Management Council, John Quinn 

Document ID: BOEM-2017-0050-49789 

The commenter expresses opposition to the inclusion of the Atlantic planning areas in the 

2019–2024 Program due to concerns that hydrocarbon development would have on marine resources and 

human communities. The commenter argues the commercial and recreational fishing industry is too 

valuable to risk any potential harm that could be caused by oil and gas drilling in the Atlantic. 

New England Fishery Management Council, Thomas Nies 

Document ID: BOEM-2017-0050-48171 

The commenter expresses opposition to the inclusion of the Atlantic planning areas in the 

2019–2024 leasing program. The commenter states that they recognized the importance of domestic 

energy development, but argued this activity in the Atlantic could jeopardize the recreational and 

commercial fishing industries that are critical to coastal economies. The commenter further argues that 

oil and gas development risks marine resources and associated human communities and requested the 

Atlantic planning areas be excluded from the most recent program. The commenter explains that 

renewable energy resource should be considered, as they will have less of an impact on marine life. 

Summaries of Public Comments A-36 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

New Jersey Conservation Foundation, Alison Mitchell 

Document ID: BOEM-2017-0050-50121 

The commenter expresses opposition to the inclusion of the North and Mid-Atlantic planning areas in the 

OCS oil and gas leasing program. The commenter urges BOEM to maintain the restriction for oil and gas 

exploration in the Atlantic. The commenter argues that there isn’t scientific evidence to support this 

policy reversal and the risks pose too significant a threat to marine life, water quality, and coastal 

communities to justify moving forward. 

New Jersey Council of Diving Club, John Fullmer 

Document ID: BOEM-2017-0050-50443 

The commenter expresses opposition to offshore oil development off the coast of New Jersey and all of 

the east coast. The commenter states that oil pollution impacts fish and marine life, and argues that ships 

will strike oil rigs should offshore drilling be developed in the region. The commenter states that offshore 

drilling will pollute the beaches of New Jersey and destroy the recreational and commercial fishing 

industry. 

North Carolina Coastal Federation, Ana Zivanovic-Nenadovic 

Document ID: BOEM-2017-0050-49555 

The commenter expresses opposition to oil and gas exploration and drilling in the Mid- and SouthAtlantic ocean. The commenter is concerned with the effects of seismic surveys on marine wildlife, and 

the potential for spills. The commenter states that oil spilled in previous disasters has persisted in oceans 

in large amounts and digested by marine organisms, compromising the health, growth and reproductions 

of many species. The commenter further argues that the tourism and recreation industries of North 

Carolina rely on healthy ecosystems, and could be compromised if these ecosystems are threatened. 

North Carolina Council of Churches, Jennifer Copeland 

Document ID: BOEM-2017-0050-48990 

The commenter expresses opposition to offshore drilling in the Atlantic and requests the Atlantic be 

permanently protected from oil and gas drilling. The commenter argues oil and gas activities threaten 

coastlands, marshes, and the habitats of countless birds and fishes. The commenter further argues that the 

likelihood of a spill is too great to justify moving forward with this program. 

Northwest Atlantic Marine Alliance, Amy MacKown 

Document ID: BOEM-2017-0050-49622 

The commenter expresses opposition to the inclusion of the Atlantic OCS in the 2019-2024 oil and gas 

leasing program. The commenter states that the health and habitats of fish species would be affected by 

offshore oil and gas exploration and development. The commenter further argues that offshore drilling 

would also pose public health risks for consumers of certain species of fish, and would interfere with 

fishing operations, impacting the industry. The commenter states that seismic exploration poses unknown 

threats to the environment and coastal zone, and that oil spills are one of the most concerning risks of 

offshore oil production. 

Summaries of Public Comments A-37 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Ocean Conservancy, National Audubon Society, Pew Charitable Trusts, WWF, Oceana, 

Andrew Hartsig 

Document ID: BOEM-2017-0050-49589 

The commenter requests that the Chukchi and Beaufort planning areas be excluded from any future oil 

and gas leasing program, and that the current 2017–2022 Program be maintained. The commenter also 

expresses support for comments submitted on behalf of local tribes and communities that request 

planning areas in the Bering Sea and North Aleutian Basin be excluded from the DPP. The commenter 

argues that the Chukchi and Beaufort Sea planning areas are vitally important for a functioning marine 

ecosystem, and that the Artic does not have the economy to support oil and gas development. The 

commenter further argues that the regions should be excluded due to limited spill response capabilities 

and a lack of drilling infrastructure. The commenter requests that BOEM address science gaps and 

consult with local tribes and communities before making leasing decisions. 

Oceana—Florida, Erin Handy 

Document ID: BOEM-2017-0050-49599 

The commenter states that offshore oil and gas exploration and drilling are neither desired nor necessary 

off the coast of Florida, and requests that no new lease sales be scheduled in the Atlantic OCS. The 

commenter states that the potential risks to marine and coastal ecosystems, tourism, fishing and recreation 

industries, and coastal communities are too great to justify new lease sales, and requests that the 

2017–2022 Program be maintained. 

Oceana—South Carolina, Samantha Siegel 

Document ID: BOEM-2017-0050-49668 

The commenter states that offshore oil and gas exploration and drilling are neither desired nor necessary 

off the coast of South Carolina, and requests that no new lease sales be scheduled in the Atlantic OCS. 

The commenter states that the potential risks to marine and coastal ecosystems, tourism, fishing and 

ocean-based recreation industries, and the coastal communities that depend on them are too great to 

justify new lease sales, and requests that the 2017–2022 Program be maintained. 

Oceana—Georgia, Samantha Siegel 

Document ID: BOEM-2017-0050-49669 

The commenter states that offshore oil and gas exploration and drilling are neither desired nor necessary 

off the coast of Georgia, and requests that no new lease sales be scheduled in the Atlantic OCS. The 

commenter argues that the potential risks to marine and coastal ecosystems, tourism, fishing and 

oceanbased recreation industries, and the coastal communities that depend on them are too great to justify 

new lease sales, and requests that the 2017–2022 Program be maintained. 

Oceana—Delaware, Caroline Wood 

Document ID: BOEM-2017-0050-49673 

The commenter states that offshore oil and gas exploration and drilling are neither desired nor necessary 

off the coast of Delaware, and requests that no new lease sales be scheduled in the Atlantic OCS. The 

commenter argues that the potential risks to marine and coastal ecosystems, tourism, fishing and 

oceanbased recreation industries, and the coastal communities that depend on them are too great to justify 

new lease sales, and requests that the 2017–2022 Program be maintained. 

Summaries of Public Comments A-38 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Oceana—Maryland, Caroline Wood 

Document ID: BOEM-2017-0050-49672 

The commenter states that offshore oil and gas exploration and drilling are neither desired nor necessary 

off the coast of Maryland, and requests that no new lease sales be scheduled in the Atlantic OCS. The 

commenter argues that the potential risks to marine and coastal ecosystems, tourism, fishing and 

oceanbased recreation industries, and the coastal communities that depend on them are too great to justify 

new lease sales, and requests that the 2017–2022 Program be maintained. 

Oceana—North Carolina, Randy Sturgill 

Document ID: BOEM-2017-0050-49690 

The commenter states that offshore oil and gas exploration and drilling are neither desired nor necessary 

off the coast of North Carolina, and requests that no new lease sales be scheduled in the Atlantic OCS. 

The commenter argues that the potential risks to marine and coastal ecosystems, tourism, fishing and 

ocean-based recreation industries, and the coastal communities that depend on them are too great to 

justify new lease sales, and requests that the 2017–2022 Program be maintained. 

Oceana—Virginia, Caroline Wood 

Document ID: BOEM-2017-0050-49690 

The commenter states that offshore oil and gas exploration and drilling are neither desired nor necessary 

off the coast of Virginia, and requests that no new lease sales be scheduled in the Atlantic OCS. The 

commenter argues that the potential risks to marine and coastal ecosystems, tourism, fishing and 

oceanbased recreation industries, and the coastal communities that depend on them are too great to justify 

new lease sales, and requests that the 2017–2022 Program be maintained. 

Oceana, Jacqueline Savitz 

Document ID: BOEM-2017-0050-51354 

The commenter requests that the Atlantic, Pacific, and Arctic oceans and the Eastern GOM be excluded 

from the proposed 2019–2024 oil and gas leasing program. The commenter also requests that the 

proposed program not include any protected areas such as National Marine Sanctuaries, Marine National 

Monuments, or withdrawn areas. The commenter states that oil spills can negatively impact marine life 

and have long-lasting impacts on ecosystems, such as the BP Horizon Oil Spill. The commenter argues 

that harms from oil and gas drilling such as oil spills, ocean acidification, and climate change outweigh 

the potential benefits. 

One Hundred Miles, Alice Keyes 

Document ID: BOEM-2017-0050-49609 

The commenter requests that the Administration uphold the 2017–2022 Program that excludes the 

Atlantic OCS. The commenter expresses concern for offshore drilling off the coast of Georgia. The 

commenter argues that the natural and historical assets found on the coast of Georgia far outweigh the 

potential benefits from offshore drilling. 

One More Generation, Olivia Ries 

Document ID: BOEM-2017-0050-24101 

The commenter expresses opposition to offshore oil and gas drilling in the Atlantic, as well as seismic 

testing. The commenter states the devastation the Deepwater Horizon spill caused should serve as 

Summaries of Public Comments A-39 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

cautionary tale for further coastal drilling. The commenter argues that oil and gas drilling could have a 

significant impact on marine life, such as dolphins and turtles. 

Plastic Ocean Project, Inc., Bonnie Monteleone 

Document ID: BOEM-2017-0050-49648 

The commenter expresses opposition to oil and gas exploration and development off the coast of North 

Carolina. The commenter expresses concern for the impacts of offshore drilling on unique fish species 

and other marine wildlife. The commenter argues that offshore drilling will be a major threat to tourism, 

which relies on charter fishing, beach recreation, hotel lodging, and restaurants. 

Santa Barbara Channelkeeper, Kira Redmond 

Document ID: BOEM-2017-0050-49631 

The commenter expresses concerned for oil and gas exploration and development in the Santa Barbara 

Channel. The commenter states that offshore drilling threatens the unique biology of the channel, as well 

as the local economy that relies on healthy marine ecosystems. The commenter states that communities 

along the channel rely on tourism, coastal recreation and the commercial fishing industry, which could be 

negatively impacted by offshore drilling. The commenter argues that offshore drilling poses other threats 

besides oil spills, such as release of wastewater, drilling muds, air pollutants and emissions. 

SC Environmental Law Project, Ameilia Thompson 

Document ID: BOEM-2017-0050-49654 

The commenter expresses concern for oil and gas exploration and development in the Atlantic OCS. The 

commenter argues that offshore drilling could threaten the commercial fishing business that relies on 

healthy populations of marketable fish, as well as the tourism industry that depends on a healthy ocean 

and attractive beaches. The commenter argues that though the oil and gas industry offers promises of 

improved technology and new regulations, these improvements cannot prohibit the 20 percent of oil spills 

resulting from human error. The commenter further argues that the Atlantic OCS residents would be 

exposed to the risks of offshore drilling with no benefits, and military training would be compromised by 

seismic and drilling equipment. 

Securing America’s Future Energy, Alexander Adams 

Document ID: BOEM-2017-0050-49608 

The commenter expresses support for oil and gas exploration and development in the Atlantic OCS as 

well as responsible energy production in the Arctic. The commenter argues that harnessing offshore 

resources will help the United States become energy independent. The commenter states that coastal 

states should have the opportunity to receive a portion of the revenue generated by offshore drilling. The 

commenter recommends retaining performance metrics regarding spills and inspections. 

Sierra Club, Michael Brune 

Document ID: BOEM-2017-0050-49655 

The commenter expresses opposition to offshore leasing and drilling in all areas for the 

2019–2024 Program. The commenter states that offshore drilling puts coastal community health, 

economic well-being, and the environment at risk. The commenter argues that drilling in the Atlantic 

would threaten popular beaches, the tourism industry, and conflict with military readiness. The 

commenter further argues that the Eastern GOM is critical for military testing and training activities, and 

drilling infrastructure would be incompatible. 

Summaries of Public Comments A-40 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Sierra Club - Croatan Group, Michael Murdoch 

Document ID: BOEM-2017-0050-49655 

The commenter expresses opposition to the new 2019–2024 offshore oil and gas lease program. The 

commenter argues that any jobs that would be apparently gained by establishing an oil and gas industry 

could mean even more jobs lost to the tourism, fishing, and recreation industries that depend on a healthy 

coast and clean oceans. The commenter offers to work with the Federal Government to help develop the 

clean energy sector in the state of North Carolina. 

South Atlantic Fishery Management Council, Michelle Duval 

Document ID: BOEM-2017-0050-08273 

The commenter expresses opposition to seismic airgun surveys in the Mid- and South-Atlantic and states 

support for BOEM’s removal of the Atlantic OCS from the 2017–2022 Program. The commenter 

describes the organization’s mandate to protect and conserve fish habitat and maintain the recreational 

and commercial fisheries along the Atlantic coast. The commenter states concern for the broader issue of 

excessive sound in the ocean and the negative impacts of noise on soundscapes and acoustic habitat of 

marine animals. 

South Carolina Wildlife Federation, Steve Gilbert 

Document ID: BOEM-2017-0050-48375 

The commenter expresses opposition to oil and gas drilling and seismic testing in the Atlantic and 

requests that the Atlantic planning areas be removed from consideration in the new OCS program. The 

commenter argues oil and gas operations pose a significant threat to marine and coastal resources, 

including marine fish and marine mammals. The commenter further argues that damage to the coast 

would impact fishing and tourism industries, which are a significant part of the South Carolina economy. 

Southern Alliance for Clean Energy, Chris Carnevale 

Document ID: BOEM-2017-0050-49545 

The commenter expresses concern for oil and gas exploration and development in the Atlantic OSC and 

GOM. The commenter requests that the Administration adheres to the lease schedule in the 

2017–2022 Program in the Atlantic and cancel remaining scheduled sales in the GOM. The commenter 

states that offshore drilling in the Atlantic will not boost energy security or independence, and would not 

generate economic gain. The commenter also states that drilling infrastructure deters tourism, which 

could impact the coastal economies, and that oil spills threaten public health. 

Southern Environmental Law Center on behalf of Cape Fear River Watch, et al., Sierra Weaver 

Document ID: BOEM-2017-0050-49667 

The commenters express opposition to oil and gas drilling and exploration in the Mid- and South Atlantic 

planning regions. The commenters state their organizations and many others spoke out and are opposed 

to including these areas during the DPP. The commenters argue that oil and gas drilling efforts could risk 

hundreds of coastal communities and fragile ecosystems along the east coast. 

Surfrider Foundation, Katie Day 

Document ID: BOEM-2017-0050-49598 

The commenter expresses opposition to offshore oil and gas drilling off the Atlantic coast, Pacific coast, 

Eastern GOM, and Alaska. The commenter requests that, should the Administration move forward with 

developing a new leasing program, BOEM take into consideration coastal communities’ reliance on 

Summaries of Public Comments A-41 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

healthy marine ecosystems for industries such as tourism, recreation, and commercial fishing. The 

commenter also requests a comprehensive review and analysis of potential impacts to both the 

environment and coastal communities. 

Surfrider Foundation, Outer Banks Chapter, Matt Walker 

Document ID: BOEM-2017-0050-49505 

The commenter expresses opposition to oil and gas leasing in the Atlantic and requests BOEM rescind the 

Atlantic lease. The commenter argues that coastal tourism and fishing already generate more jobs than 

the estimated number of jobs oil and gas leasing was estimated to bring. The commenter further argues 

the risk of a spill is too great, and that coastal communities would likely have a difficult time recovering 

from a spill. The commenter states that North Carolina could be a good candidate for offshore wind 

energy development and suggests that BOEM instead invest in clean and renewable energy programs. 

Texas Conservative Coalition Research, John Colyandro 

Document ID: BOEM-2017-0050-19215 

The commenter expresses support for the inclusion of all 26 OCS planning areas in the DPP. The 

commenter argues that there is large energy potential in the oil reserves currently off limits to production. 

The commenter further argues that expanding domestic energy production would reduce dependence on 

foreign oil and increase both economic and energy security in the United States 

The CLEO Institute, Caroline Lewis 

Document ID: BOEM-2017-0050-50876 

The commenter expresses opposition to oil and gas drilling and seismic testing in the waters off the coast 

of Florida, as well as the Arctic and Atlantic OCS. The commenter argues that offshore drilling puts the 

waters and coastal communities at risk of oil spill, and worsens climate change. The commenter states 

that clean energy is the fastest-growing and cheapest source of energy. 

The Nature Conservancy, Stephanie Bailenson 

Document ID: BOEM-2017-0050-49597 

The commenter expresses opposition to expanding lease sales and offshore drilling in the Atlantic OCS. 

The commenter expresses concern for the ecological significance and vulnerability of coastal and marine 

resources and requests that BOEM provide special consideration for protected species and sensitive 

habitats. The commenter also expresses concerns about the industry’s ability to mitigate the risks of oil 

spills and the spill response capabilities. 

The Wilderness Society, Lois Epstein 

Document ID: BOEM-2017-0050-49658 

The commenter requests that lease sales in the Arctic Ocean be excluded from the 2019–2024 proposed 

leasing program. The commenter urges the Department exclude additional lease sales in the Beaufort 

Seas planning area. The commenter argues that the Arctic Region is at risk for a large spill that the 

United States does not have the resources to properly clean up. The commenter requests that BOEM 

engage Arctic residents and tribes during OCS planning and decisionmaking. The commenter 

recommends that quantification of potential GHG emissions, as well as an analysis of climate change 

impacts, be integrated into the NEPA analysis conduction for the new program. 

Summaries of Public Comments A-42 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Turtle Island Restoration Network, Andrew Ogden 

Document ID: BOEM-2017-0050-49647 

The commenter states that a new oil and gas leasing program is unnecessary and flawed. The commenter 

is concerned about offshore drilling in the Arctic OCS and argues that oil and gas development will 

exacerbate warming in the Arctic. The commenter also states that the United States is unprepared and 

unable to clean up a spill in the Arctic waters, and requests that the Chukchi and Beaufort planning areas 

remain off limits. The commenter also states that the Department of Defense (DOD) and Congressional 

representatives are opposed to expanded lease sales in the GOM. 

Voces Verdes, Adrienna Quintero 

Document ID: BOEM-2017-0050-50891 

The commenter expresses opposition to expanded oil and gas drilling in the Atlantic and Arctic OCS. 

The commenter states that offshore drilling poses risks to oceans, beaches, and marine life, as well as 

coastal communities that depend on healthy oceans for fishing, recreation, and the revenue from tourism. 

The commenter argues that clean energy is now the fastest-growing and cheapest source of power in the 

country. 

Wildlife Conservation Society, Angela Noakes 

Document ID: BOEM-2017-0050-49637 

The commenter urges BOEM to ensure that the new National OCS Program continues to provide the 

necessary protections for important coastal and ocean ecosystems and wildlife. The commenter states 

that offshore drilling and seismic testing poses risks such as noise, increased ship traffic, and spill that 

threaten marine wildlife, coastal economies, and unique ecosystems in the Atlantic and Arctic OCS. The 

commenter requested that stakeholders be engaged throughout the planning process. 

World Wildlife Fund—U.S. Arctic Program, Margaret Williams 

Document ID: BOEM-2017-0050-49657 

The commenter expresses opposition to the inclusion of the Arctic in the 2019–2024 leasing program and 

urges BOEM maintain the exclusion of the North Aleutian Basin planning area. The commenter argues 

that the risk of spill in the Arctic is large, and the spill response capabilities are lacking. The commenter 

also states that fossil fuel demand is declining and offshore drilling would exacerbate climate change in 

the Arctic region. 

A.4 FEDERAL AGENCIES 

Department of Commerce, National Oceanic and Atmospheric Administration 

Document ID: BOEM 2017-0050-51339 

The Department of Commerce is generally supportive of involvement in the new program, and states that 

the Department’s assets related to ocean resources science and stewardship are located within NOAA, 

who prepared input for the recent RFI, which was attached to the letter. In the attachment titled “NOAA 

Input re: NOEM National OCS Program 2019–2024 Request for Information,” NOAA states they will 

provide BOEM with science-based guidance for development of mitigation measures necessary to 

minimize impacts on marine resources, per statutory mandates related to the Endangered Species Act, 

Marine Mammal Protection Act, the National Marine Sanctuaries Act, Coastal Zone Management Act, 

and the Magnuson-Stevens Fishery Conservation and Management Act. NOAA encourages BOEM to 

collaborate proactively to identify and evaluate potential impacts to living marine resources. NOAA 

Summaries of Public Comments A-43 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

identifies five recommendations for consideration: shoreside infrastructure, response capabilities, joint 

vulnerability research, use of buffer zones, and data access. NOAA also identifies tools to support 

characterizing the OCS: Environmental Setting and Conditions in National Marine Sanctuaries, NOAA 

Environmental Sensitivity Index, Environmental Response Management Application, and Essential Fish 

Habitat Mapper Tool (links to documents provided in attachment). 

Department of Defense 

Document ID: BOEM-2017-0050-49738 

The DOD fully supports the development of energy resources in a manner compatible with military 

operations, readiness, and the safety of military personnel and the public. The commenter states that 

DOD supports further analysis of the established uses of the OCS prior to proposing a lease sale in the 

Mid- and South Atlantic Program Area and will continue to work collaboratively with USDOI, BOEM, 

and other stakeholders. The commenter states that DOD is prepared to provide additional information 

and continue its close cooperation on offshore energy development. 

Department of Homeland Security, U.S. Coast Guard 

Document ID: BOEM- 2017-0050-49830 

The U.S. Coast Guard is generally supportive of its collaborative partnership with BOEM for all energy 

development initiatives in the new program, and recognized their recently completed Atlantic Coast Port 

Access Route Study that will assist with better coordinated activities requiring extraordinary 

consideration in maritime regions to strengthen the Nation’s infrastructure, energy independence, and 

economy. 

Department of Justice 

Document ID: BOEM- 2017-0050-49739 

The Department of Justice has no additional comments to provide but expresses support in collaboration 

and development of the new National Program. 

Department of State 

Document ID: BOEM- 2017-0050-49829 

The Department of State has no additional comments to provide but is generally supportive of 

involvement and collaboration on the new Program, as necessary. 

Department of Transportation 

Document ID: BOEM- 2017-0050-49831 

The Department of Transportation generally supports safe and reliable methods of transportation 

associated with oil and gas production in all waters and air space of the program planning areas, and 

acknowledges overlapping interest that oil and gas producers, marine and pipeline operators, and aviators 

transport products safely on the OCS, as well as the adequacy and availability of transportation 

infrastructure. The commenter references the Deepwater Port Act of 1974 where the Department of 

Transportation is the lead licensing authority for development of offshore deepwater ports. 

Marine Mammal Commission 

Document ID: BOEM-2017-0050-49639 

The Marine Mammal Commission encourages BOEM to undertake a comprehensive analysis of the 

Nation’s energy needs and the relative costs and benefits of meeting those needs from a variety of 

Summaries of Public Comments A-44 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

renewable and non-renewable energy sources. The Commission supports maintaining the current 

2017–2022 schedule of lease sales, with the exception of the proposed lease sale in Cook Inlet. The 

Commission encourages BOEM to re-evaluate its methodology for estimating and using non-market 

values for protected species. The Commission recommends several ways in which BOEM could improve 

its analyses, including the incorporation of new information regarding the effects of oil spills on marine 

mammals. The Commission cites concern for the beluga whale population in Cook Inlet, recommends 

that BOEM maintain the December 2016 Presidential withdrawal areas in the Chukchi Sea and Beaufort 

Sea, recommends that BOEM support the collection of additional data on subsistence use patterns, 

recommends continued restriction of leasing in the Eastern GOM Planning Area, and recommends 

exclusion of all Pacific planning areas. 

National Aeronautics and Space Administration 

Document ID: BOEM-2017-0050-19625 

The National Aeronautics and Space Administration (NASA) expresses concern regarding oil and gas 

leasing near the facility’s launch and flight operations, and states that their primary concern with future 

oil and gas development that could result in the need to protect additional persons and property when 

conducting launch operations in the Atlantic Ocean, as well as suborbital launch operations in the Poker 

Flat Research Range in Alaska. The commenter’s areas of greatest concern on the OCS are the Mid- and 

South Atlantic and Beaufort Sea planning areas. The commenter references its own mission impact 

assessment as a cooperating agency in the 2017–2022 OCS Oil and Gas Leasing Program Programmatic 

Environmental Impact Study (EIS), and will provide input to BOEM. The commenter intends on active 

participation in the new Program and requests designation as a cooperating agency when Programmatic 

EIS preparation begins, noting that efforts have begun to update their previously submitted 

2017–2022 Program mission impact assessment. 

National Marine Fisheries Service, Alaska Region, Habitat Conservation Division 

Document ID: BOEM- 2017-0050-49822 

The Habitat Conservation Division states that Alaska does not currently have a CZM Program to manage 

its Federal BOEM planning areas in the Alaska OCS, and supports the need for collaboration on future 

studies and risk assessments. The commenter recognizes that large data gaps exist with regard to marine 

fisheries and habitat in Alaska and are working towards filling these gaps by identifying studies needed to 

better inform management decisions. The commenter remains consistent in affirming that the moratoria 

for the North Aleutian Basin remain in place. The commenter suggests conducting assessments in the 

proposed planning areas using an Ecosystem Based Management approach to incorporate “scientific 

advice on fisheries, development, energy, ecotourism, conservation, sanctuaries, and other relevant 

factors.” The commenter notes that Arctic conditions will change, which could create an increase in 

vessel traffic in an area where emergency response capabilities are limited, which BOEM should take into 

consideration. The commenter also states the possible increased anthropogenic footprint in the area in the 

event of oil and gas development, which should yield analysis of effects on marine and estuarine habitat 

areas. The commenter specifically notes that differences between the Cook Inlet planning area and the 

Chukchi and Beaufort Sea planning areas, which could be assessed using the Ecosystem Based 

Management approach to understand interactions within and between ecosystems. The commenter 

references their updated Impacts to Essential Fish Habitat from Non-fishing Activities report that provides 

general recommended conservation measures for oil and gas exploration and development options to 

avoid and minimize adverse impacts. 

Summaries of Public Comments A-45 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

U.S. Environmental Protection Agency 

Document ID: BOEM- 2017-0050-49832 

The U.S. Environmental Protection Agency has no comments to provide, but is generally supportive of 

involvement in the new program, and offers assistance with facilitating and coordinating input on the new 

program as well as the Draft Programmatic EIS. 

A.5 ENERGY EXPLORATION & PRODUCTION INDUSTRY AND ASSOCIATIONS 

API, NOIA, IPAA, USOGA, IADC, IAGC, AOGA 

Document ID: BOEM-2017-0050-49552 

The American Petroleum Institute (API), National Ocean Industries Association (NOIA), Independent 

Petroleum Association of America (IPAA), U.S. Oil and Gas Association (USOGA), International 

Association of Drilling Contractors (IADC), International Association of Geophysical Contractors 

(IAGC), Alaska Oil and Gas Association (AOGA), and Petroleum Equipment & Services Association 

(PESA) state their support for inclusion of all OCS areas with the potential to generate jobs and new 

revenue. They specifically state their full support of keeping existing areas of the GOM and Alaska 

available for leasing and urge BOEM to make new areas in the Atlantic, Eastern GOM, Beaufort and 

Chukchi Seas of Alaska, and the Pacific available for leasing as part of the program. The commenters 

encourage BOEM to include all 26 planning areas in the DPP for further evaluation to ensure that an area 

is not eliminated from consideration prematurely. 

Anadarko Petroleum Corporation 

Document ID: BOEM-2017-0050-49701 

Anadarko Petroleum Corporation urges BOEM to keep existing areas in the GOM available for leasing 

and additionally make new areas available, particularly the Mid- and South Atlantic and the Eastern 

GOM. The commenter asks BOEM to consider 10-year initial lease periods for all deep water leases, 

with the potential for additional time for development in frontier areas. They also ask BOEM to consider 

lowering royalty rates for all water depths to match the recent change in waters less than 200 meters deep. 

Arctic Slope Regional Corporation (ASRC) Exploration, LLC (AEX) 

Document ID: BOEM-2017-0050-49623 

AEX applauds BOEM’s efforts to reevaluate their 2017–2022 Leasing Program and propose the 

2019–2024 Leasing Program include the Arctic Planning Areas. AEX strongly encouraged the inclusion 

of the Arctic Planning Areas in the 2017–2022 Leasing Program and was disappointed by BOEM’s 

decision to exclude the Arctic in the 2017–2022 Program. The commenter encourages BOEM, in 

analyzing Arctic Leases, to consider potential impacts on subsistence as well as the success of existing 

mitigation measures like the Conflict Avoidance Agreement. The commenter notes that including the 

lease sales in the Arctic in the 2019–2024 Program can offset the current production and economic 

decline and promote business development and investments across the North Slope, including needed 

infrastructure. 

BP Exploration & Production Inc. 

Document ID: BOEM-2017-0050-49595 

BP supports the Obama Administration’s “all-of-the-above” energy plan, which includes renewables, 

while recognizing the key role of oil and gas resources from the OCS in meeting the Nation’s energy 

needs. The commenter believes BOEM should not only expand access for exploration and production but 

Summaries of Public Comments A-46 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

should also provide lease and royalty flexibility in consideration of the economic and technological 

challenges faced in the OCS. The commenter supports including an Atlantic OCS lease sale in 2020, 

which will encourage more industry participation to future seismic acquisition programs. The commenter 

also supports holding region-wide lease sales in the GOM, but suggests adjusting the cadence to one lease 

sale per year, preferably in May. 

Chevron U.S.A., Inc. 

Document ID: BOEM-2017-0050-49497 

Chevron U.S.A., Inc. states that the Federal Government should move expeditiously to open unavailable 

submerged lands with believed resource potential for exploration and development. They rank planning 

areas in order of priority, starting with the Central, Western, and Eastern GOM planning areas being 

ranked first, second, and third, respectively. The commenter notes that while there is limited current 

information, the Atlantic is of some interest, with the Mid-, North, and South Atlantic ranked fourth, fifth, 

and sixth, respectively. The Southern California Planning area was ranked seventh. 

Cobalt International Energy 

Document ID: BOEM-2017-0050-49592 

Cobalt fully supports keeping all existing exploration and production areas in the GOM and Alaska in the 

DPP and strongly recommends that at this point in the development of 2019–2024 Five Year Program, all 

26 planning areas of the OCS be considered for inclusion in the DPP, including areas currently under a 

temporary moratorium, like the Eastern GOM. Additionally, the commenter notes BOEM’s change in 

royalty rates for shallow water and requests BOEM consider a similar reduction for all new leases in all 

water depths. The commenter also recommends BOEM discontinue its “7-years-plus-three-years” lease 

term for water depths from 800 to 1,600 meters, believing that it is prudent, due to new rules and 

regulations, to provide a full 10 year lease term for all waters greater than 800 meters. 

Diamond Offshore 

Document ID: BOEM-2017-0050-49736 

Diamond Offshore states that it is important that all 26 OCS planning areas are fully explored to discover 

the oil and gas potential. The commenter specifically mentions the potential of the Atlantic OCS, Eastern 

GOM, and the Beaufort and Chukchi Seas offshore Alaska. 

Enven Energy Ventures 

Document ID: BOEM-2017-0050-48038 

Enven Energy Ventures is supportive of the inclusion of all 26 planning areas in the development of the 

DPP. The commenter strongly supports the inclusion of the Eastern GOM, along with the continued 

inclusion of the Central and Western GOM. They focus on the GOM due to the ability to realize quick 

and impactful results, with the Eastern GOM residing in close proximity to existing infrastructure and the 

existence of available seismic data would allow for quick resource development with minimal footprint. 

Shell Oil Company 

Document ID: BOEM-2017-0050-49563 

Shell strongly recommends the Secretary make new OCS areas available to assess the extent of United 

States energy resources as expeditiously as practicable. The commenter cites the 2017–2022 Program 

analysis that showed the national benefits of offshore oil and gas production outweigh potential risks and 

was disappointed that the previous Administration denied access to most planning areas outside of the 

Summaries of Public Comments A-47 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

GOM and therefore urges this administration to quickly replace the current National OCS Program and 

grant access to new areas. 

Statoil USA E & P, Inc. 

Document ID: BOEM-2017-0050- 49643 

Statoil believes that at this point in the Program development process, all OCS areas with the potential to 

generate jobs and new revenue should be considered for inclusion in the DPP. The commenter fully 

supports keeping existing areas in the GOM and Alaska available for leasing in the 2019–2024 Program 

and also urges BOEM to make new areas in the Atlantic, Eastern GOM, and the Pacific available for 

leasing as part of the Program. The commenter also recommends that the Program only include one 

GOM areawide sale per year, as opposed to the current Program, which offers two GOM areawide sales. 

A.6 NON-ENERGY EXPLORATION & PRODUCTION INDUSTRY AND 

ASSOCIATIONS 

Airlines for America, John Hiemlich 

Document ID: BOEM-2017-0050-46462 

The commenter expresses support for the development of a new leasing program and urged the inclusion 

of all 26 OCS planning areas in the Draft Proposed Program. The commenter states that billions of 

barrels of undiscovered resources exist in Federal waters that could help meet the Nation’s oil and natural 

gas needs for more than a decade as well as contribute to job creation, increased government revenue, and 

Gross Domestic Product. 

Alaska Chamber, Curtis Thayer 

Document ID: BOEM-2017-0050-08652 

The commenter expresses support for the development of a new leasing program and specifically requests 

that the Beaufort and Chukchi Seas in the Arctic OCS be included. The commenter argues that these 

areas hold an overabundance of oil and gas resource that would provide jobs for the region and aid the 

United States in solidifying energy security. The commenter further argues that the development of 

Alaska’s OCS would maintain the TAPS as a critical link in energy distribution. Finally, the commenter 

states that there is strong support among Alaska residents for offshore exploration and production of oil 

and gas. 

Alaska Chamber of Commerce, et al., Christopher Guith 

Document ID: BOEM-2017-0050-49656 

The commenter expresses support for expansion of offshore leases in the eastern Gulf of Mexico, Alaska, 

and the Atlantic for energy development. The commenter argues offshore energy development is critical 

for long-term energy security. The commenter explains continued and expanded offshore oil and gas 

exploration will help the United States remain competitive in the energy market. 

Alaska District Council of Laborers, A.J. Merrick 

Document ID: BOEM-2017-0050-49580 

The commenter expresses support for the inclusion of the Beaufort and Chukchi Seas as well as other 

expanded leasing opportunities in the DPP. The commenter argues development of the OCS in Alaska 

will help lead to energy security and independence, as well as job creation and state revenue. The 

commenter explains that there are large quantities of oil in the Alaskan OCS that are currently restricted 

Summaries of Public Comments A-48 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

from development. The commenter further states development of the Alaskan OCS will enhance the 

long-term viability of the TAPS. 

Alaska Longline Fisherman’s Association, et al., Karen Gillis 

Document ID: BOEM-2017-0050-49617 

The commenter expresses support for the existing withdrawal of the Bristol Bay and the North Aleutian 

Basin, and urges these areas remain excluded from the 2019–2024 Program. The commenter explains 

that the commercial fishing industry in Alaska accounts for nearly half of domestic seafood production 

and employ tens of thousands of Alaskans. The commenter argues that the fishing industry, as well as 

many other valuable Alaskan industries, depends on clean water. 

Alaska Longline Fisherman’s Association, et al., Karen Gillis 

Document ID: BOEM-2017-0050-49617 

The commenter expresses support for the existing withdrawal of the Bristol Bay and the North Aleutian 

Basin, and urges these areas remain excluded from the 2019–2024 Program. The commenter explains 

that the commercial fishing industry in Alaska accounts for nearly half of domestic seafood production 

and employ tens of thousands of Alaskans. The commenter argues that the fishing industry, as well as 

many other valuable Alaskan industries, depends on clean water. 

Alaska Trucking Association, Aves Thompson 

Document ID: BOEM-2017-0050-09835 

The commenter expresses support for developing a new leasing program and urged the inclusion of 

26 OCS planning areas in the development of the DPP. The commenter expresses that Alaskan offshore 

development would create business and job opportunities for the transportation industry and trucking 

companies in particular. The commenter argues that the immense resources available in the Alaskan OCS 

would generate jobs and significant government revenue. The commenter further argues that the 

development of Alaska’s OCS would maintain the TAPS and support American energy independence. 

Alyeska Pipeline Service Co., Tom Barrett 

Document ID: BOEM-2017-0050-47651 

The commenter expresses support for expanded access to offshore oil and gas leasing, especially in the 

Beaufort and Chukchi Seas in Alaska. The commenter argues that increased oil and gas development in 

the Alaskan Artic will help increase the longevity of the TAPS. The commenter explains that TAPS has 

been operating below capacity and this inactivity is creating issues for maintaining the structure. 

American Chemistry Council, Owen Kean 

Document ID: BOEM-2017-0050-08706 

The commenter expresses support for developing a new leasing program and urged the inclusion of 

26 OCS planning areas in the development of the DPP. The commenter argues that the exclusion of any 

planning areas at this initial phase would be premature and threaten the Nation’s energy security. The 

commenter describes the various uses of natural gas in manufacturing and chemical industries and the 

economic impact of allowing oil and gas development in offshore areas. 

Summaries of Public Comments A-49 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

American Forest & Paper Association, Jerry Schwartz 

Document ID: BOEM-2017-0050-49653 

The commenter expresses support for developing a new leasing program and urged the inclusion of all 

26 OCS planning areas in the development of the DPP. The commenter argues that excluding regions 

from leasing consideration without critical environmental analysis would be premature and harm efforts 

to ensure American energy security. The commenter states that the United States is currently only 

utilizing 20 percent of its oil reserves, and development of these areas could result in half a million jobs 

and billions of dollars in government revenue. 

American Highway Users Alliance, Gregory Cohen 

Document ID: BOEM-2017-0050-10121 

The commenter expresses support for the development of a new leasing program and urged the inclusion 

of all 26 planning areas in the DPP. The commenter argues that offshore resource development provides 

significant economic impact for states, citing the revenue and jobs created in the GOM. The commenter 

also states that economic gains from oil and gas development would trickle through the economy of the 

entire country. 

American Iron and Steel Institute (AISI), Thomas J. Gibson 

Document ID: BOEM-2017-0050-49607 

The commenter expresses support for the inclusion of all 26 planning areas, especially the Atlantic, 

Alaskan and Eastern Gulf of Mexico areas, in the development of the Draft Proposed Program. The 

commenter explains the Atlantic planning area has the potential to product billions of barrels of oil and 

trillions of cubic feet of natural gas, providing significant energy and economic benefits. The commenter 

argues the Gulf of Mexico has served as an example of safe energy development and supports 

maintaining all lease sales in the Gulf. The commenter also argues that restrictions on development in the 

Beaufort and Chukchi seas should be lifted so the large quantity of untapped oil and gas can be utilized. 

The commenter argues increased domestic energy development will increase energy security and 

stimulate the economy. 

American Society of Landscape Architects, Nancy Somerville 

Document ID: BOEM-2017-0050-49584 

The commenter opposes expanding oil and gas exploration beyond the scope of the current leasing 

program. The commenter argues offshore oil and gas exploration is already contributing to GHG 

emissions and should be reduced to minimize our impact on climate change. The commenter further 

argues that oil and gas development would impact recreation and tourism economies that rely on healthy 

coasts. 

Associated General Contractors of Alaska, John MacKinnon 

Document ID: BOEM-2017-0050-47888 

The commenter expresses support for including all 26 OCS planning areas in the development of the 

DPP. In addition to boosting U.S. economic growth, the commenter stated offshore development in 

Alaska would extend the longevity of the TAPS, which further ensure the Nation’s energy security. 

Summaries of Public Comments A-50 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Associated Industries of Florida, Brewster Bevis 

Document ID: BOEM-2017-0050-49520 

The commenter expresses support for the inclusion of the Atlantic OCS in the 2019–2024 OCS Leasing 

Program. The commenter argues that the economic impact of offshore oil and gas development would 

benefit Florida residents and businesses. The commenter states support for the expansion of 

revenuesharing to states beyond the GOM. 

Bald Head Association, Judy Porter 

Document ID: BOEM-2017-0050-49590 

The commenter requests BOEM retain the current 2017–2022 OSC leasing program, including 

maintaining the exclusion of the Atlantic OCS. The commenter argues offshore oil and gas exploration 

would negatively impact their community in coastal North Carolina. 

Bayou Industrial Group, Denny Borne 

Document ID: BOEM-2017-0050-47958 

The commenter expresses support for developing a new leasing program and urged the inclusion of 

26 OCS planning areas in the development of the DPP. The commenter cites existing sites in the GOM 

as examples of offshore drilling operations that are safe and productive as well as environmentally 

responsible. The commenter argues that Federal waters hold immense recourses that could greatly benefit 

the Nation’s economy if access would be granted. 

C + L Creative, Laura Butcher 

Document ID: BOEM-2017-0050-09829 

The commenter expresses support for the development of a new leasing program and urged the inclusion 

of all 26 planning areas in the DPP. The commenter argues that offshore resource development provides 

significant economic impact for states, citing the revenue and jobs created in the GOM. The commenter 

also states that economic gains from oil and gas development would trickle through the economy of the 

entire country. 

Cape May County Chamber of Commerce, Vicki Clark 

Document ID: BOEM-2017-0050-49967 

The commenter expresses opposition to the development of a new leasing program, the opening of the 

Atlantic OCS to offshore development, and related activities including seismic testing. The commenter 

argues that vulnerable and unique habitats that exist along the coast would be threatened if offshore oil 

and gas development were allowed in the Atlantic. The commenter states further that development of 

resources along the coast would impose unwanted infrastructure development on the area and would 

negatively impact the commercial and residential fishing industries. 

Carteret County Chamber of Commerce, Tom Kies 

Document ID: BOEM-2017-0050-49967 

The commenter expresses opposition to seismic testing and offshore oil drilling in the Atlantic OCS. 

Caterpillar Inc., Wayne Zemke 

Document ID: BOEM-2017-0050-10113 

The commenter expresses support for the development of a new leasing program and urged the inclusion 

of all 26 planning areas in the DPP. The commenter argues that offshore resource development provides 

Summaries of Public Comments A-51 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

significant economic impact for states, citing the revenue and jobs created in the GOM. The commenter 

also states that economic gains from oil and gas development would trickle through the economy of the 

entire country. 

Chemical Industry Council of Illinois, Mark Biel 

Document ID: BOEM-2017-0050-08631 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter argues offshore oil and gas resource development in 

the Atlantic, Alaskan Arctic, and GOM could result in hundreds of thousands of jobs and billions of 

dollars in government revenue. The commenter further argues the country’s economic and energy 

security is dependent on expanding oil and gas resource use. 

Chickasaw Distributors, Inc., Brad Baker 

Document ID: BOEM-2017-0050-50907 

The commenter urges a new National Program be developed with maximum access to all offshore 

resources. The commenter argues that allowing access to areas currently off-limits to oil and gas 

production could result in hundreds of thousands of jobs and billions of dollars in government revenue. 

The commenter further argues offshore development is vital to ensuring American energy dominance and 

decreasing or eliminating reliance on foreign oil. 

Clay County Chamber of Commerce, Doug Conkey 

Document ID: BOEM-2017-0050-49516 

The commenter expresses support for inclusion of all the Atlantic OCS planning areas in the development 

of the 2019–2024 DPP. The commenter argues prematurely excluding the planning areas in the Atlantic 

would deny businesses and citizens of the coast the opportunity to understand the benefits and 

opportunity drilling in this region would allow. The commenter further argues that in order for the United 

States to move towards energy independence and energy security, it is necessary to explore all of the 

energy resources. 

Committee of 100 for Economic Development, Inc., Michael Olivier 

Document ID: BOEM-2017-0050-45770 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter states that excluding regions under consideration at 

the beginning of the process without critical environmental analysis would be premature and hurt 

American energy security. The commenter argues oil and gas production in the Gulf of Mexico shows 

the economic and energy benefits development can bring to a region, and that expanded access to the Gulf 

of Mexico will only help the economies of the Gulf Region. 

COOL Environmental Consulting, Patrick Cotter 

Document ID: BOEM-2017-0050-49636 

The commenter expresses opposition to the 2019–2024 OCS Oil and Gas Leasing Program. The 

commenter argues the new OCS program jeopardizes marine sanctuaries and other sensitive marine 

environments. The commenter argues this activity could also violate Federal or state environmental laws 

and regulations. 

Summaries of Public Comments A-52 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Covington County Chamber of Commerce, Marie Shoemake 

Document ID: BOEM-2017-0050-08485 

The commenter expresses support for the development of a new leasing program and urged the inclusion 

of all 26 planning areas in the DPP. The commenter argues that offshore resource development provides 

significant economic impact for states, citing the revenue and jobs created in the GOM. The commenter 

also states that economic gains from oil and gas development would trickle through the economy of the 

entire country. 

Dare County Tourism Board and Outer Banks Visitors Bureau, Susie Walters and Lee Nettles 

Document ID: BOEM-2017-0050-48610 

The commenter expresses opposition to offshore oil and gas exploration and seismic testing off the coast 

of North Carolina. The commenter argues that offshore resource development would negatively impact 

the tourism industry that is critical to the economy of the region. The commenter states that tourism and 

the oil and gas industries cannot coexist. 

Elite Parking, Dane Grey 

Document ID: BOEM-2017-0050-49509 

The commenter expresses support for the inclusion of all planning areas in the initial planning phase, 

notably the Arctic OCS. The commenter argues oil and gas development in the Gulf of Mexico is critical 

to the economy of Florida, creating and sustain jobs and generating state revenue. 

Energy Industries of Ohio, Robert M. Purgert 

Document ID: BOEM-2017-0050-49581 

The commenter states support for the development of a new leasing program and urges the inclusion of 

all 26 planning areas in the DPP. The commenter states that immense reserves of oil and gas in these 

areas would help businesses and increase the quality of life for Americans. The commenter argues that 

developing resources in U.S. waters that are subject to strict safety and regulatory requirements would 

help protect the environment, instead of relying on imports from countries with less strict standards. 

Ensco, Brady 

Document ID: BOEM-2017-0050-49744 

The commenter expresses support for expanding offshore oil and gas development and exploring all 

26 OCS regions using seismic testing to determine the full OCS potential of the United States. The 

commenter argues that oil and gas development is a vital part of the Texas and national economies, 

employing tens of thousands of workers, and generating billions of dollars in state and Federal revenue. 

The commenter argues it is necessary to at least explore the potential of regions such as the Alaskan 

Arctic to understand the full energy potential of the United States. 

Garden Club of Virginia, Wendy Vaughn 

Document ID: BOEM-2017-0050-49546 

The commenter expresses opposition to offshore oil and gas exploration and drilling off the coast of 

Virginia and all planning areas in the Atlantic OCS, as well as seismic airgun blasting. The commenter 

explains these leasing areas were removed from the 2017–2022 Program after consideration of public 

comment and relevant economic and environmental factors, and requests the current program not be 

modified. The commenter argues that ocean-based industries are too valuable to risk for the sake of oil 

and gas drilling. 

Summaries of Public Comments A-53 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Gate Petroleum Company, Buzz Hoover 

Document ID: BOEM-2017-0050-49517 

The commenter expresses support for the development of a new OCS leasing program and urges the 

inclusion of all Atlantic planning areas in the DPP. The commenter argues that development of the 

Atlantic could result in hundreds of thousands of jobs and billions of dollars in state and Federal revenue. 

The commenter states that seismic estimates of the oil supply in the Atlantic OCS are more than 30 years 

old and should be updated. The commenter argues that the economic and energy security of the United 

States depends on utilizing all available energy sources. 

Georgia Chamber of Commerce, Clark 

Document ID: BOEM-2017-0050-49751 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all Atlantic OCS planning areas in the development of the DPP. The commenter argues development 

of the Atlantic OCS could result in hundreds of thousands of jobs and billions of dollars in government 

revenue. The commenter explains long-term economic and energy security in the United States requires 

access to the Nation’s abundant natural resources. 

Georgia Association of Manufacturers, G.L. Bowen 

Document ID: BOEM-2017-0050-49534 

The commenter expresses support for the development of a new leasing program, and more specifically 

for the inclusion of the Atlantic OCS. The commenter cites the creation of jobs, additional economic 

activity, and generation of government revenue as reasons to open the Atlantic OCS to leasing. The 

commenter argues that the limitation of planning areas in the early stages of draft program development is 

not appropriate. The commenter further argues that oil and gas development in OCS areas will help 

ensure American energy security and reduce the trade deficit. 

Greater Iberia Chamber of Commerce, Janet Faulk Gonzales 

Document ID: BOEM-2017-0050-19464 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter states that excluding regions under consideration at 

the beginning of the process without critical environmental analysis would be premature and hurt 

American energy security. The commenter argues that offshore resource development provides 

significant economic impact for states, citing the revenue and jobs created by offshore resource 

development in the GOM. 

Greater New Orleans Inc., Michael Hecht 

Document ID: BOEM-2017-0050-49603 

The commenter expresses support for the development of a new leasing program and urges inclusion of 

all 26 planning areas in the DPP. The commenter states that excluding regions under consideration at the 

beginning of the process without critical environmental analysis would be premature and hurt American 

energy security. The commenter argues that offshore resource development provides significant 

economic impact for states, citing the revenue and jobs created by offshore resource development in the 

GOM. 

Summaries of Public Comments A-54 January 2018 
 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Greater Port Arthur Chamber of Commerce, William McCoy 

Document ID: BOEM-2017-0050-08345 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter argues that offshore resource development provides 

significant economic impact for states, citing the revenue and jobs created in the GOM. The commenter 

also stated that economic gains from oil and gas development would trickle through the economy of the 

entire country. 

Greater Tomball Area Chamber of Commerce, Bruce Hillegeist 

Document ID: BOEM-2017-0050-49508 

The commenter states support for the development of a new leasing program and urges the inclusion of 

all 26 planning areas in the DPP. The commenter argues that offshore oil and gas development is 

intimately tied to the region and pursuing development further would greatly benefit the community’s 

economy. 

Hooper Family Seafood, Penny Hooper 

Document ID: BOEM-2017-0050-29775 

The commenter expresses opposition to offshore oil and gas drilling in the Atlantic Ocean. The 

commenter argues that offshore development would harm the environment and economy of the North 

Carolina coast, further arguing that the jobs created by oil and gas drilling are often filled by imported 

labor. The commenter also states that there is an inherent responsibility to protect and preserve the 

environment for future generations. 

Houma-Terrebonne Chamber of Commerce, Suzanne Nolfo Carlos 

Document ID: BOEM-2017-0050-10044 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter argues that offshore resource development provides 

significant economic impact for states, citing the revenue and jobs created in the GOM. The commenter 

also states that economic gains from oil and gas development would trickle through the economy of the 

entire country. 

Illinois Chamber of Commerce, Katie Stonewater 

Document ID: BOEM-2017-0050-49557 

The commenter states support for the development of a new leasing program and urges the inclusion of 

all 26 planning areas in the DPP. The commenter states that immense reserves of oil and gas in these 

areas would help businesses and increase the quality of life for Americans. The commenter argues that 

developing resources in U.S. waters that are subject to strict safety and regulatory requirements would 

help protect the environment, instead of relying on imports from countries with less strict standards. 

Industrial Energy Consumers of America, Paul Cicio 

Document ID: BOEM-2017-0050-49572 

The commenter expresses support for expanding oil and gas development in the GOM, Alaska, and the 

Atlantic Coast. The commenter supports an “all-of-the-above” approach to energy policy and argues 

utilizing the OCS of the United States could contribute to economic and energy security. 

Summaries of Public Comments A-55 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Jacksonville Axemen Rugby League, Drew Slover 

Document ID: BOEM-2017-0050-49510 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter states that excluding regions under consideration at 

the beginning of the process without critical environmental analysis would be premature and hurt 

American energy security. The commenter argues that offshore resource development provides 

significant economic benefits for the State of Florida, leads to lower travel costs for tourists, and 

increased spending power for residents. 

JAX Chamber, Christopher Quinn 

Document ID: BOEM-2017-0050-24553 

The commenter expresses support for the inclusion of the South Atlantic planning areas that were 

previously removed, in the development of a new leasing program. The commenter cites the economic 

impacts of opening the Atlantic to offshore drilling, including the creation of jobs and increased economic 

activity. The commenter requests that BOEM investigate the inclusion of the Atlantic rigorously and not 

dismiss the viability of the region outright. 

Lime Instruments, Rob Stewart 

Document ID: BOEM-2017-0050-28738 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP, specifically leases off the coast of Texas. The commenter states that 

excluding regions under consideration at the beginning of the process without critical environmental 

analysis would be premature and hurt American energy security. The commenter argues that offshore 

resource development provides significant economic impact for states, citing the revenue and jobs created 

by offshore resource development in the GOM. 

Louisiana Mid-Continent Oil Gas Association and the Louisiana Association of Business 

and Industry, Lori LeBlanc 

Document ID: BOEM-2017-0050-49561 

The commenter expresses support for the development of a new leasing program that includes exploration 

of leasing in the Mid- and South Atlantic, Eastern GOM, and the Pacific. The commenter states the 

expansion of territories would help meet energy demands and cites the economic benefits experienced by 

Louisiana and GOM area, including protection of natural resources, tourism, and coastal communities. 

The commenter recommends BOEM evaluate opportunities to reduce royalty rates for current and future 

leases in the GOM. 

Louisiana Oil Marketers Convenience Store Association, Natalie Isaacks 

Document ID: BOEM-2017-0050-18515 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter argues that offshore resource development provides 

significant economic impact for states, citing the revenue and jobs created in the GOM. The commenter 

requests BOEM increase oil and gas leasing within the GOM for the benefit of the coastal states. The 

commenter also stated that economic gains from oil and gas development would trickle through the 

economy of the entire country. 

Summaries of Public Comments A-56 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Lynden Inc., Jeanine St John 

Document ID: BOEM-2017-0050-08716 

The commenter expresses support for continued lease sales in the Alaska OCS and urges the inclusion of 

all 26 planning areas in the development of the DPP. The commenter states that lease sales within the 

Arctic could support the TAPS and would positively impact the economy of the region. The commuter 

argues that the subsistence and environmental impacts of offshore development could be mitigated 

through responsible drilling practices and that the untapped resources of the Alaskan OCS would support 

an energy-independent America. The commenter also states that the lease sales by BOEM represent 

stability and predictability that allow industry to engage in long-term strategies to pursue offshore 

resources. 

Manufacture Alabama, George Clark 

Document ID: BOEM-2017-0050-08615 

The commenter expresses support for the development of a new leasing program and urges inclusion of 

all 26 planning areas in the DPP. The commenter argues that offshore resource development provides 

significant economic impact for states, citing the revenue and jobs created in the GOM. The commenter 

also states that economic gains from oil and gas development would trickle through the economy of the 

entire country. 

Marine & Industrial, Steve Barker 

Document ID: BOEM-2017-0050-49641 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP, specifically leases off the coast of Alabama. The commenter states 

that excluding regions under consideration at the beginning of the process without critical environmental 

analysis would be premature and hurt American energy security. The commenter argues that offshore 

resource development provides significant economic impact for states, citing the revenue and jobs created 

by offshore resource development in the GOM. 

Mexico Beach Charters, BBT, LLC, Recreational Fishing Alliance-Forgotten Coast Chapter, 

Captain Tom Adams 

Document ID: BOEM-2017-0050-08616 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter argues that offshore resource development provides 

significant economic impact for states, citing the revenue and jobs created in the GOM. The commenter 

also states that economic gains from oil and gas development would trickle through the economy of the 

entire country. 

Mississippi Farm Bureau Federation, A. Whittington 

Document ID: BOEM-2017-0050-49512 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter argues that offshore resource development provides 

significant economic impact for states, citing the revenue and jobs created in the GOM. The commenter 

also states that economic gains from oil and gas development would trickle through the economy of the 

entire country. 

Summaries of Public Comments A-57 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Mississippi Manufacturers Association, Jay Moon 

Document ID: BOEM-2017-0050-46794 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter states that excluding regions under consideration at 

the beginning of the process without critical environmental analysis would be premature and hurt 

American energy security. The commenter argues that offshore resource development provides 

significant economic impact for states, citing the revenue and jobs created by offshore resource 

development in the GOM. 

Mobile Area Chamber of Commerce, William Sisson 

Document ID: BOEM-2017-0050-08434 

The commenter expresses support for expanding oil and gas exploration in the GOM, Alaska, and the 

Atlantic. The commenter argues if more areas are opened to offshore exploration and development, the 

resulting economic activity and energy production could do great things for our Gulf coast region and the 

Nation. The commenter argues offshore oil and gas exploration is safer than ever, and increased 

exploration will help strengthen national and energy security. 

National Association of Charterboat Operators, Capt. Bob Zales, II 

Document ID: BOEM-2017-0050-10040 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter argues that offshore resource development provides 

significant economic impact for states, citing the revenue and jobs created in the GOM. The commenter 

also stated that economic gains from oil and gas development would trickle through the economy of the 

entire country. 

National Association of Manufacturers, Ross Eisenberg 

Document ID: BOEM-2017-0050-49567 

The commenter expresses support for expanded lease access to the OCS, including the Eastern GOM, 

Pacific, Atlantic, and Alaska. The commenter argues to move the country forward in energy security and 

independence, all options need to be explored and expanded, including renewable energy and oil and gas 

exploration. The commenter further argues allowing seismic surveys in the Atlantic, Eastern GOM, and 

Pacific would allow policy makers, manufacturers, and other stakeholders to understand the potential 

resources these areas hold. The commenter explains that developing additional oil and gas resources will 

grow the economy and help create jobs. 

NACS, Paige Anderson 

Document ID: BOEM-2017-0050-29603 

The commenter expresses support for developing a new leasing program and urges the inclusion of all 

26 OCS planning areas in the development of the DPP. The commenter supports policies that ensure a 

stable domestic supply of energy, such as the DPP. The commenter notes that many of the energy 

resources are in inaccessible areas in the Atlantic, Alaskan Arctic, and GOM. 

New Orleans Chamber of Commerce, G. Ben Johnson 

Document ID: BOEM-2017-0050-46948 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter states that excluding regions under consideration at 

Summaries of Public Comments A-58 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

the beginning of the process without critical environmental analysis would be premature and hurt 

American energy security. The commenter argues that offshore resource development provides 

significant economic impact for states, citing the revenue and jobs created by offshore resource 

development in the GOM. 

North Star Terminal & Stevedore Co. LLC, Scott Vierra 

Document ID: BOEM-2017-0050-19527 

The commenter expresses support for the continued leasing of the Arctic OCS. The commenter argues 

that current oil and gas drilling in the region has been done in an environmentally sound manner. The 

commenter states that excluding the Alaskan OCS could jeopardize long-term energy and economic 

security of the Nation. 

North Star Terminal & Stevedore Co. LLC, Steven Post 

Document ID: BOEM-2017-0050-19476 

The commenter expresses support for the continued leasing of the Arctic OCS. The commenter argues 

that current oil and gas drilling in the region has been done in an environmentally sound manner. The 

commenter states that excluding the Alaskan OCS could jeopardize long-term energy and economic 

security of the Nation. 

Ohio AgriBusiness Association, Christopher Henney 

Document ID: BOEM-2017-0050-08715 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter argues that offshore oil and gas resource 

development in the Atlantic, Alaskan Arctic, and the GOM could result in hundreds of thousands of jobs 

and billions of dollars in government revenue. The commenter further argues that the country’s economic 

and energy security is dependent on expanding oil and gas resource use. 

Ohio Cast Metals Association, Kevin Schmidt 

Document ID: BOEM-2017-0050-08717 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter argues that offshore oil and gas resource 

development in the Atlantic, Alaskan Arctic, and GOM could result in hundreds of thousands of jobs and 

billions of dollars in government revenue. The commenter further argues that the country’s economic and 

energy security is dependent on expanding oil and gas resource use. 

One Acadiana, Andre Breaux 

Document ID: BOEM-2017-0050-08514 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter argues that offshore resource development provides 

significant economic impact for states, citing the revenue and jobs created in the GOM. The commenter 

also states that economic gains from oil and gas development would trickle through the economy of the 

entire country. 

Summaries of Public Comments A-59 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Pacific Drilling Services Inc. 

Document ID: BOEM-2017-0050-49594 

The commenter expresses its support of the proposed development of a new National OCS Oil and Gas 

Leasing Program for 2019–2024. It is important that all 26 OCS regions are fully explored to delineate 

their oil and gas potential. The Atlantic OCS is estimated to contain 4.72 billion barrels of oil and 

37.5 trillion cubic feet of natural gas, while the Eastern Gulf of Mexico holds an estimated 5.07 billion 

barrels of oil and 16.08 trillion cubic feet of natural gas. These amounts represent more than 20 times the 

2012 Federal offshore oil production and more than 94 times the 2012 Federal offshore natural gas 

production. In the Arctic, it is vital that the United States maintains and accelerates opportunities to 

develop offshore oil and gas in the resource rich Beaufort and Chukchi seas. The region holds an 

estimated 23.6 billion barrels of oil and 104 trillion cubic feet of natural gas. It is strategically important 

that these estimates be refined. 

Panama City Boatmen Association, Captain Bob Zales, II 

Document ID: BOEM-2017-0050-10041 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter argues that offshore resource development provides 

significant economic impact for states, citing the revenue and jobs created in the GOM. The commenter 

also states that economic gains from oil and gas development would trickle through the economy of the 

entire country. 

Partnership for Affordable Clean Energy, Laura Schepis 

Document ID: BOEM-2017-0050-08863 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter argues that offshore oil and gas resource 

development in the Atlantic, Alaskan Arctic, and GOM could result in hundreds of thousands of jobs and 

billions of dollars in government revenue. The commenter further argued the country’s economic and 

energy security is dependent on expanding oil and gas resource use. 

Peassal Operating Company, Peassal 

Document ID: BOEM-2017-0050-49797 

The commenter expresses opposition to offshore drilling in the Atlantic coast. The commenter argues 

fishing and tourism industries are vital to the economy of North Carolina and rely on healthy coasts. The 

commenter further argues that little net benefit would come from this activity. 

Petroleum Marketers Association of America, Rob Underwood 

Document ID: BOEM-2017-0050-08885 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter argues that offshore oil and gas resource 

development in the Atlantic, Alaskan Arctic, and GOM could result in hundreds of thousands of jobs and 

billions of dollars in government revenue. The commenter further argues that the country’s economic and 

energy security is dependent on expanding oil and gas resource use. 

Summaries of Public Comments A-60 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Pink Petro, Katie Mehnert 

Document ID: BOEM-2017-0050-10122 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter argues that offshore resource development provides 

significant economic impact for states, citing the revenue and jobs created in the GOM. The commenter 

also states that economic gains from oil and gas development would trickle through the economy of the 

entire country. 

Ports Association of Louisiana, David Allain 

Document ID: BOEM-2017-0050-30022 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter argues that the exclusion of any planning areas at 

this initial phase, before critical environmental analysis, would be premature and threaten the Nation’s 

energy security. The commenter further argues that continued and expanded leasing within the GOM 

would provide jobs and increase state revenue. 

Public Lands Council, Dave Eliason 

Document ID: BOEM-2017-0050-49649 

The commenter expresses support for the development a new leasing program and urges the inclusion of 

all 26 OCS planning areas in the development of the DPP. The commenter argues that excluding regions 

from leasing consideration at the outset and without critical environmental analysis would be premature 

and harm efforts to ensure American energy security. 

Resource Development Council, Carl Portman 

Document ID: BOEM-2017-0050-48544 

The commenter expresses support for the development of a new leasing program and urges BOEM to 

expand access to the Beaufort and Chukchi Seas and the greater Arctic OCS that were restricted by the 

2017–2022 Program. The commenter also requests that BOEM consider the expansion of leasing in the 

GOM and Atlantic OCS. The commenter argues that these areas hold immense resources that would 

greatly benefit the American economy and stabilize energy production. The commenter further argues 

that oil and gas production in the Arctic would support the TAPS and allow the pipeline to remain viable 

in the long-term. The commenter states that impacts on subsistence living and the environment could be 

mitigated through the use of new technology. 

Rig-Chem, LLC, Lori Davis 

Document ID: BOEM-2017-0050-48950 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter argues that offshore resource development provides 

significant economic impact for states, citing the revenue and jobs created in the GOM. The commenter 

also states that economic gains from oil and gas development would trickle through the economy of the 

entire country. 

Rowan Companies, Michael Lawson 

Document ID: BOEM-2017-0050-08875 

The commenter expresses support for the development of a new National OCS oil and gas leasing 

program for 2019–2024. A robust offshore energy program is important to businesses offering offshore 

Summaries of Public Comments A-61 January 2018 
 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

contract drilling services and support hundreds of thousands of jobs. Opening offshore production areas 

would help businesses as well as support U.S. goals of energy dominance. 

Saltchuk, Harry McDonald 

Document ID: BOEM-2017-0050-49600 

The commenter expresses support for the inclusion of Arctic Leases in the 2019–2024 Program. The 

commenter states many industries in Alaska are dependent on oil and gas development, including 

shipping and transportation industries. The commenter argues new OCS leases will provide economic 

opportunity for decades to come. The commenter states the people of Alaska are interested in sustainable 

development of these regions as well. 

Sealark Investments, Inc., John Schwarz, Jr. 

Document ID: BOEM-2017-0050-18892 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter argues that offshore resource development provides 

significant economic impact for states, citing the revenue and jobs created in the GOM. The commenter 

also states that economic gains from oil and gas development would trickle through the economy of the 

entire country. 

SolstenXP, Inc., Jesse Mohrbacher 

Document ID: BOEM-2017-0050-49543 

The commenter states that the State of Alaska is dependent on continued access to oil and gas resources 

including state and local governments, native tribes, and public health and safety. The Beaufort and 

Chukchi Seas have extensive oil and gas resources, and the North Slope provides existing pipeline 

infrastructure, including the TAPS. The commenter suggests BOEM consider the past record of safe 

OCS well development and government oversight when assessing environmental safety and sensitivity in 

Alaskan Arctic waters, the state and Federal economic benefits associated with Arctic OCS oil and gas 

development, and the importance of OCS oil development to secure America’s energy needs. 

South Carolina Chamber of Commerce, Ted Pitts 

Document ID: BOEM-2017-0050-47020 

The commenter urges BOEM to approve additional offshore leases when developing the 2019–2024 

Program. The commenter argues that more offshore exploration and leasing would increase America’s 

energy independence, leading to an increase in economic stability for employers and improving national 

security. 

South Carolina Manufacturers Alliance, Lewis Gossett 

Document ID: BOEM-2017-0050-49815 

The commenter expresses support for developing a new leasing program and urges the inclusion of all 

Atlantic OCS planning areas in the development of the DPP. The commenter argues development of the 

Atlantic OCS could result in hundreds of thousands of jobs and billions of dollars in government revenue. 

The commenter further argues including the Atlantic planning areas would allow for economic and 

environmental analyses to be conducted to know the full benefits development in this area could offer. 

Summaries of Public Comments A-62 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

South Carolina Small Business Chamber of Commerce, Frank Knapp 

Document ID: BOEM-2017-0050-49573 

The commenter expresses opposition to offshore oil drilling in the Atlantic. The commenter states that 

experiences in the Gulf of Mexico and Pacific are examples of the harm an oil spill can have on coastal 

communities and economies, including impacts to beaches and tourism. The commenter reminds BOEM 

that the decision to open the Atlantic to offshore drilling would have a lasting impact on marine animals 

and coastal economies. 

South Central Industrial Association, Jane Arnette 

Document ID: BOEM-2017-0050-49519 

The commenter expresses support for the National OCS Oil and Gas Leasing Program including 

allowance of leasing in current and new areas where potential resources are unknown, such as the Midand South-Atlantic. The commenter states south Louisiana is home to the country’s leading ports in the 

oil and gas industry and vitality of the area’s economy. The commenter states the oil and gas industry can 

safely coexist with shipping, commercial and recreation fishing, tourism, and military activity. The 

commenter recommends BOEM issue permits for the collection of new Atlantic seismic data to replace 

the aging information upon which current decisions are based. 

Southern Chemical Corporation, Jan Spin 

Document ID: BOEM-2017-0050-08612 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter argues offshore oil and gas resource development in 

the Atlantic, Alaskan Arctic, and GOM could result in hundreds of thousands of jobs and billions of 

dollars in government revenue. The commenter further argued the country’s economic and energy 

security is dependent on expanding oil and gas resource use. 

South Louisiana Economic Council, Vic Lafont 

Document ID: BOEM-2017-0050-47944 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter argues that offshore resource development provides 

significant economic impact for states, citing the revenue and jobs created in the GOM. The commenter 

also states that economic gains from oil and gas development would trickle through the economy of the 

entire country. 

St. Mary Chamber of Commerce, Donna Meyer 

Document ID: BOEM-2017-0050-08650 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter argues that offshore resource development provides 

significant economic impact for states, citing the revenue and jobs created in the GOM. The commenter 

also stated that economic gains from oil and gas development would trickle through the economy of the 

entire country. 

St. Tammany West Chamber of Commerce, Lacey Toledano 

Document ID: BOEM-2017-0050-08441 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter argues that offshore resource development provides 

Summaries of Public Comments A-63 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

significant economic impact for states, citing the revenue and jobs created in the GOM. The commenter 

also states that economic gains from oil and gas development would trickle through the economy of the 

entire country. 

Steel Tank Institute-Steel Plate Fabricators Association, Wayne Geyer 

Document ID: BOEM-2017-0050-17231 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter argues offshore oil and gas resource development in 

the Atlantic, Alaskan Arctic, and GOM could result in hundreds of thousands of jobs and billions of 

dollars in government revenue. The commenter further argued the country’s economic and energy 

security is dependent on expanding oil and gas resource use. 

Steve Pratt Enterprises, Steve Pratt 

Document ID: BOEM-2017-0050-19240 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter argues that offshore development, specifically in the 

Beaufort and Chukchi Seas would bolster the United States economy and establish the country as a top 

energy producer. The commenter also argues that Alaskan offshore development would extend the 

longevity of the TAPS and help the United States achieve energy self-sufficiency. 

Texas Association of Business, Stephen Minick 

Document ID: BOEM-2017-0050-08343 

The commenter expresses support for the development of a new leasing program and urges BOEM to 

include all 26 planning areas in the initial draft program. The commenter argues that increased access to 

offshore resources will strengthen the national economy while reducing the cost of energy for businesses 

and citizens. The commenter cites past development in the GOM as a demonstration of the contributions 

of oil and gas leasing on local, regional, and state economies. 

Texas Association of Manufacturers, Richard Bennett 

Document ID: BOEM-2017-0050-08437 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter argues that offshore resource development provides 

significant economic impact for states, citing the revenue and jobs created in the GOM. The commenter 

also states that economic gains from oil and gas development would trickle through the economy of the 

entire country. 

Texas Trucking Association 

Document ID: BOEM-2017-0050-19243 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter states that excluding regions under consideration at 

the beginning of the process without critical environmental analysis would be premature and hurt 

American energy security. The commenter argues that offshore resource development provides 

significant economic impact for states, citing the revenue and jobs created by offshore resource 

development in the GOM. 

Summaries of Public Comments A-64 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Teyatech Inc., Ron Perry 

Document ID: BOEM-2017-0050-49663 

The commenter expresses support for the inclusion of Arctic OCS lease areas, specifically the Beaufort 

and Chukchi seas, in the OCS Oil and Gas 2019–2024 Program. The commenter argues the oil and gas 

resources in this region could mean hundreds of jobs for Alaskans, as well as revenue for the state. The 

commenter further argues oil and gas development in the Arctic Sea would increase the viability of the 

TAPS. 

The Plaza Group, Randy Velarde 

Document ID: BOEM-2017-0050-08704 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter argues that offshore resource development provides 

significant economic impact for states, citing the revenue and jobs created in the GOM. The commenter 

also states that economic gains from oil and gas development would trickle through the economy of the 

entire country. 

The Town Dock, Katie Almeida 

Document ID: BOEM-2017-0050-49569 

The commenter expresses opposition to exploration or leasing in the North Atlantic. The commenter 

expresses concern for the impact that pollution from chemicals used during the drilling process could 

have on those whose businesses depend on a healthy ocean ecosystem. The commenter supports a 

moratorium on both exploration and drilling in the North Atlantic. 

The State Chamber of Commerce Mississippi Economic Council, Scott Waller 

Document ID: BOEM-2017-0050-49601 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter states that excluding regions under consideration at 

the beginning of the process without critical environmental analysis would be premature and hurt 

American energy security. The commenter argues that offshore resource development provides 

significant economic impact for Mississippi, citing the revenue and jobs created by offshore resource 

development in the GOM. 

Thibodaux Chamber of Commerce, Cody J Blanchard 

Document ID: BOEM-2017-0050-49823 

The commenter expresses support for developing a new leasing program and incorporating all 26 OCS 

planning areas. The commenter argues further development of the GOM could result in hundreds of 

thousands of jobs and billions of dollars in government revenue. The commenter further argues OCS 

development can occur alongside other industries, just as it does with Louisiana’s fishing industry. 

Transocean, Bond 

Document ID: BOEM-2017-0050-49825 

The commenter expresses support for the proposed development of a new National OCS Oil and Gas 

Leasing Program for 2019–2024. A robust offshore energy program would be important to drilling 

businesses as well as the entire U.S. economy and energy security. The commenter supported seismic 

testing in all 26 OCS regions. 

Summaries of Public Comments A-65 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Transportation Institute, Andrew Strosahl 

Document ID: BOEM-2017-0050-08860 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter argues offshore oil and gas resource development in 

the Atlantic, Alaskan Arctic, and GOM could result in hundreds of thousands of jobs and billions of 

dollars in government revenue. The commenter further argues the country’s economic and energy 

security is dependent on expanding oil and gas resource use. 

Udelhoven Oilfield System Services, Inc., Jim Udelhoven 

Document ID: BOEM-2017-0050-27985 

The commenter expresses support for including all 26 OCS planning areas in the development of the 

DPP, specifically Federal waters off Alaska. The commenter explained that it is vital for Alaska and the 

Nation to maintain opportunities to develop oil and natural gas off Alaska, including Beaufort and 

Chukchi Seas. In addition to benefiting the U.S. economy, Alaskan offshore development will help 

extend the longevity of the TAPS. 

Virginia Beach Hotel Association, Diana Burke 

Document ID: BOEM-2017-0050-48508 

The commenter expresses opposition to offshore drilling in the Atlantic Ocean, and more specifically off 

the coast of Virginia. The commenter explains that the risk of environmental harm represents a liability 

that coastal communities cannot assume, given the heavy reliance on the tourism industry. The 

commenter states that more cohesive, substantive, and unbiased information is needed on the impacts of 

offshore drilling and that the communities of the Virginia coast cannot support a decision on drilling until 

that research is provided. 

Virginia Beach Restaurant Association, Laura Habr William Gambrell 

Document ID: BOEM-2017-0050-48473 

The commenter states opposition to all offshore oil and gas exploration or drilling off the coast of 

Virginia, including the use of seismic airgun blasting surveys. The commenter argues that the Atlantic 

OCS region was removed from the 2017–2022 Program after careful consideration and BOEM should not 

modify the current program. The commenter states concern over the potential for oil spills and the impact 

of offshore drilling on the environment and tourism industry. 

Virginia Chamber of Commerce, Barry DuVal 

Document ID: BOEM-2017-0050-08630 

The commenter expresses support for the development of a new leasing program and urges BOEM to 

include all 26 planning areas in the initial draft program. The commenter argues that the Atlantic OCS 

holds significant oil reserves that would help the United States achieve long-term energy security and 

reduce the trade deficit with other countries. The commenter also argues that the projected revenue 

generation from oil and gas development has only increased since the previous seismic surveys were 

conducted. 

Virginia Manufacturers Association, Brett Vassey 

Document ID: BOEM-2017-0050-49562 

The commenter expresses support for including all planning areas, including the entire Atlantic OCS in 

the DPP. The commenter argues development of the Atlantic OCS could result in hundreds of thousands 

Summaries of Public Comments A-66 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

of jobs and billions of dollars in public revenue, with significant benefits in Virginia. The commenter 

states current seismic estimates are out of date and new surveys should be conducted to accurately 

estimate the full potential of the Atlantic planning areas. The commenter argues developing Atlantic OCS 

would help bring economic and energy security to the east coast and the United States. 

Virginia Petroleum Council, Miles Morin 

Document ID: BOEM-2017-0050-51199 

The commenter expresses support for the expansion of oil and gas leasing and development in the OCS. 

The commenter argues that the U.S. needs to take full advantage of the potential benefits that offshore 

exploration and production can bring, such as economic activity, new jobs, and stable energy prices. The 

commenter further argues that offshore drilling will strengthen the national security of the United States. 

Vivlamore Companies, Frontier Supply Company, Sunrise Bagel & Espresso, MV Investments, 

The Showcase, Regency Fairbanks Hotel, Tubby’s, Bill Vivlamore 

Document ID: BOEM-2017-0050-18863 

The commenter expresses support for the development of a new leasing program and urges BOEM to 

include all 26 planning areas in the initial draft program. The commenter expresses disappointment on 

the removal of the Alaskan OCS from the 2017–2022 Program and urges the inclusion of the Beaufort 

and Chukchi Seas. The commenter argues that the area holds immense reserves that could produce 

economic benefits but access to these areas is extremely limited. The commenter further argues that the 

development of Alaska’s OCS would maintain the TAPS and support American energy independence. 

W.D. Scott Group, Inc., William Scott 

Document ID: BOEM-2017-0050-08657 

The commenter expresses support for the development of a new leasing program and urges inclusion of 

all 26 planning areas in the DPP. The commenter argues that offshore resource development provides 

significant economic impact for states, citing the revenue and jobs created in the GOM. The commenter 

also states that economic gains from oil and gas development would trickle through the economy of the 

entire country. 

Wisconsin Industrial Energy Group, Todd Stuart 

Document ID: BOEM-2017-0050-49536 

The commenter expresses support for the inclusion of all 26 OCS planning areas in the DPP. The 

commenter states it is premature to exclude regions without first conducting environmental analysis. The 

commenter states opening currently off-limit areas in the Atlantic, Alaskan Arctic, and GOM would 

ensure cost effective and environmentally sound domestic energy. 

Wrightsville Beach Chamber of Commerce, Susan Bulluck 

Document ID: BOEM-2017-0050-50118 

The commenter states that if offshore oil and gas drilling would pose a risk to critical economic sectors, 

then it should be avoided at all costs. The commenter explains that the tourism and fishing industries are 

the cornerstone of the coastal economy and states that alternative energy sources should be pursued if 

traditional energy would threaten local businesses and jobs. 

Summaries of Public Comments A-67 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

A.7 STATE-LEVEL ELECTED OFFICIALS 

Fourteen Members of the North Carolina House of Representatives 

Document ID: BOEM-2017-0050-49788 

Fourteen members of the North Carolina House of Representatives express support for the inclusion of 

the Atlantic in the 2019–2024 Program and state that North Carolina would benefit from oil and natural 

gas development as it would provide jobs and generate substantial economic activity within the state. The 

commenters urge the prompt approval of pending applications to conduct seismic surveys and support the 

expansion of revenue-sharing. 

Alabama State House of Representatives, Lynn Greer 

Document ID: BOEM-2017-0050-62531 

The commenter expresses support for the development of a new leasing program and the consideration of 

all 26 Offshore Planning Areas during this initial phase. The commenter argues U.S. waters contain great 

quantities of oil that can help support state and Federal economies through revenue sharing and job 

growth. The commenter further argues that expanded access to planning areas in the GOM will increase 

economic gain for Alabama and the entire Gulf coast. 

Alabama State House of Representatives, Victor Gaston 

Document ID: BOEM-2017-0050-21466 

The commenter expresses support for developing a new leasing program and urges the inclusion of all 

26 OCS planning areas in the development of the DPP. The commenter argues that excluding regions 

from leasing consideration at the outset and in the absence of critical environmental analysis would be 

premature and harm efforts to ensure American energy security. 

Alabama State Senator, Steve Livingston 

Document ID: BOEM-2017-0050-24755 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP, specifically leases off the coast of Alabama. The commenter states 

that excluding regions under consideration at the beginning of the process without critical environmental 

analysis would be premature and hard American energy security. The commenter argues that offshore 

resource development provides significant economic impact for states, citing the revenue and jobs created 

in the GOM. 

Alabama State House of Representatives, David. R. Sessions 

Document ID: BOEM-2017-0050-49699 

The commenter expresses support for the consideration of all 26 offshore planning areas during this initial 

phase of the program. The commenter argues that U.S. waters contain great quantities of oil that can help 

support state and Federal economies through revenue sharing and job growth. The commenter further 

argues expanded access to planning areas in the GOM will increase economic gain for Alabama and the 

entire Gulf coast. 

Alaska State House of Representatives, Charisse Millet 

Document ID: BOEM-2017-0050-19997 

The commenter expresses support for considering all 26 OCS leasing areas in the development of the new 

DPP, especially the Beaufort and Chukchi Seas in Alaska that were ultimately removed from the 

Summaries of Public Comments A-68 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

2017-2022 Program. The commenter argues the development of Alaska’s OCS would create jobs and 

increase economic growth in not just the state, but in the entire country as well. The commenter further 

argues this development is supported by the majority of the residents of Alaska. 

Alaska State House of Representatives, Chris Birch 

Document ID: BOEM-2017-0050-23205 

The commenter requests BOEM reconsider all unleased areas of the Beaufort and Chukchi in the DPP 

and more specifically, those areas in the Beaufort and Chukchi that were originally included but later 

removed from the 2017–2022 Program. The commenter argues the development of Alaska’s OCS would 

prolong the lifespan of TAPS primarily by providing more oil to transport through its system. The 

commenter argues the development of offshore resources would also create tens of thousands of jobs and 

increase economic growth in the region. 

Alaska Legislature, Senator Cathy Giessel 

Document ID: BOEM-2017-0050-08621 

The commenter requests BOEM reconsider all unleased areas of the Beaufort and Chukchi in the DPP; 

more specifically, those areas in the Beaufort and Chukchi that were originally included and then later 

removed from the 2017–2022 Program. The commenter argues the development of Alaska’s OCS would 

prolong the lifespan of TAPS primarily by providing more oil to transport through its system. The 

commenter argues this development would also create tens of thousands of jobs and increase economic 

growth in the region. 

Alaska State Senate, John Coghill 

Document ID: BOEM-2017-0050-25099 

The commenter expresses support for lease sales in the Beaufort and Chukchi Seas and urges that the 

Hanna Shoal area to be opened up for leasing again. The commenter argues that the development of these 

areas in Alaska could create tens of thousands of jobs and generate revenue for the state and the Federal 

Government as well as aid the United States in becoming a global top energy producer. 

Alaska State Senate, Pete Kelly 

Document ID: BOEM-2017-0050-63786 

The commenter expresses support for the development of a new leasing program and requests BOEM 

reconsider all unleased areas of the Beaufort and Chukchi in the DPP. The commenter argues the 

development of Alaska’s OCS would prolong the lifespan of TAPS primarily by providing more oil to 

transport through its system. The commenter further argues the development of offshore resources would 

also create tens of thousands of jobs and increase economic growth in the region. 

Alaska State Senate, Kevin Meyer 

Document ID: BOEM-2017-0050-49711 

The commenter requests that BOEM consider all 26 OCS leasing areas in the development of the DPP. 

The commenter argues the development of Alaska’s OCS would prolong the lifespan of TAPS primarily 

by providing more oil to transport through its system. This development would also create jobs and 

increase economic growth in the region. 

Summaries of Public Comments A-69 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

California State Senate, Daniel Alavarez 

Document ID: BOEM-2017-0050-49720 

The commenter submits a resolution opposing oil and gas leasing in the Pacific OCS. The commenter 

argues that California’s fishing, tourism, and recreation industries are too valuable to risk harming with 

oil and gas development and activity. The commenter requests the Pacific OCS be permanently 

safeguarded by the President and Congress. 

California State Senate, Senator Mike McGuire 

Document ID: BOEM-2017-0050-26830 

The commenter expresses opposition to the new leasing program. The commenter notes the proposal 

ignores the opinions of west coast residents who have expressed opposition to new oil and gas drilling. 

The commenter suggests opening the coasts of California, Oregon, and Washington would threaten the 

livelihood of millions. 

Energy Producing States Coalition, Senator Chuck Winder 

Document ID: BOEM-2017-0050-08714 

The commenters express support for including all offshore planning areas as part of the 

2019–2024 leasing program. The commenters argue that resource potential in the Atlantic, Alaskan 

Arctic, and GOM could create hundreds of thousands of jobs, and billions of dollars in spending and 

revenue for both states and the Federal Government. 

Florida House of Representatives, Jason Fischer 

Document ID: BOEM-2017-0050-19076 

The commenter expresses support for including the Atlantic in future oil and natural gas development 

programs and expanding revenue-sharing to all states with adjacent offshore oil and gas activity. The 

commenter also supports approval of pending applications to conduct Atlantic oil and gas seismic 

exploration and issue related permits as well. 

Georgia State Senator Frank Ginn 

Document ID: BOEM-2017-0050-49515 

The commenter expresses support for exploration and leasing in the Atlantic. The commenter argues that 

resource potential in the Atlantic could create hundreds of thousands of jobs, and billions of dollars in 

spending and revenue for both states and the Federal Government. The commenter further argues 

prematurely excluding the Atlantic planning areas from the DPP and the subsequent cost-benefit analyses 

that follow would deny the citizens and governments of the Atlantic States the ability to realize the 

potential benefits of oil and gas activity. 

Georgia State House of Representatives, Don Parsons 

Document ID: BOEM-2017-0050-19076 

The commenter expresses support for including all offshore planning areas as part of the 

2019–2024 leasing program. The commenter argues that resource potential in the Atlantic, Alaskan 

Arctic, and GOM could create hundreds of thousands of jobs, and billions of dollars in spending and 

revenue for both states and the Federal Government. 

Summaries of Public Comments A-70 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Georgia House of Representatives, Jason Spencer 

Document ID: BOEM-2017-0050-54471 

The commenter expresses support for the development of a new leasing program for 2019–2024 to 

include all planning areas, especially the Atlantic OCS. The commenter argues that tapping into the 

resource potential in the Atlantic could create hundreds of thousands of jobs, and billions of dollars in 

spending and revenue for both states and the Federal Government. The commenter further argues that use 

of these resources will help lead to long-term energy security. 

Georgia State Representative, Charles Martin 

Document ID: BOEM-2017-0050-49521 

The commenter expresses support for including all planning areas, especially the Atlantic planning areas, 

in the 2019–2024 leasing program. The commenter argues that resource potential in the Atlantic could 

create hundreds of thousands of jobs, and billions of dollars in spending and revenue for both states and 

the Federal Government. The commenter further argues that use of these resources will help lead to 

longterm energy security. 

Mississippi State Senate, Angela Burks Hill 

Document ID: BOEM-2017-0050-48217 

The commenter expresses support for the consideration of all 26 offshore planning areas during this initial 

phase of program development. The commenter argues that U.S. waters contain great quantities of oil 

that can help support state and Federal economies through revenue sharing and job growth. The 

commenter further argues that expanded access to planning areas in the GOM will increase economic 

gain for Mississippi and the entire Gulf coast. 

Mississippi State House of Representatives, Gary V. Staples 

Document ID: BOEM-2017-0050-49786 

The commenter supports the consideration of all 26 offshore planning areas during this initial phase of the 

program. The commenter argues that U.S. waters contain great quantities of oil that can help support 

state and Federal economies through revenue sharing and job growth. The commenter further argues that 

expanded access to planning areas in the GOM will increase economic gain for the entire Gulf coast. 

Mississippi State Senate, Charles Younger 

Document ID: BOEM-2017-0050-17334 

The commenter expresses support for developing a new leasing program and urged the inclusion of 

26 OCS planning areas in the development of the DPP. The commenter argues that excluding regions 

from leasing consideration at the outset and in the absence of critical environmental analysis would be 

premature and harm efforts to ensure American energy security. 

Mississippi State Senate, President Pro Tempore Terry Burton 

Document ID: BOEM-2017-0050-08651 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter argues that offshore resource development provides 

significant economic impact for states, citing the revenue and jobs created in the Gulf of Mexico. The 

commenter also states that economic gains from oil and gas development would trickle through the 

economy of the entire country. 

Summaries of Public Comments A-71 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

New Jersey General Assembly, Timothy Eustace 

Document ID: BOEM-2017-0050-57292 

The commenter expresses opposition to any offshore drilling for oil and gas, and specifically the leasing 

and development-related activities off the coast of New Jersey. The commenter states that the New 

Jersey tourism industry and recreational and commercial fishing industry would be at risk due to offshore 

oil and gas exploration and drilling. The commenter argues further that the United States should reduce 

its dependence on fossil fuels and move towards renewable energy sources. 

New Jersey State Senate, Bob Smith 

Document ID: BOEM-2017-0050-56540 

The commenter expresses opposition to the development of a new offshore leasing program, and 

specifically opposes oil and gas leasing and related activities off the coast of New Jersey. The commenter 

states that a new National OCS Program is unwarranted and unwelcome. The commenter also states that 

the risks from oil and gas development, exploration and production would negatively impact the 

environment and economy of New Jersey as well as the livelihoods of its citizens. 

New Jersey 11th Legislative District Monmouth County, Eric Houghtaling and Joann Downey 

Document ID: BOEM-2017-0050-49660 

The commenters express opposition to any efforts to expand oil and gas drilling in the Atlantic Ocean, 

which could threaten New Jersey’s coastal communities. The commenters state that the arguments made 

against oil and gas drilling in the Atlantic OCS for the current program are still relevant today. The 

commenters state that an oil spill, like Deepwater Horizon, could cause damage to the economy, coastal 

communities, and coastal resources, as well as threaten endangered species and reduce the quality of life 

for New Jersey residents. 

South Carolina General Assembly, Chip Campsen III and assembly members 

Document ID: BOEM-2017-0050-57359 

Thirty-two members of the South Carolina General Assembly express opposition to the inclusion of the 

Mid- and South-Atlantic planning areas in the 2019–2024 Program. The commenters state that offshore 

drilling poses serious risks to the unique environment and tourism industry of South Carolina as well as 

the quality of life of its residents. The commenters also state that the infrastructure development 

associated with offshore drilling would severely impact the residential and resort development and 

impede the protection of important wildlife refuges. 

South Carolina House of Representatives, Jason Elliott 

Document ID: BOEM-2017-0050-48456 

The commenter expresses opposition to the inclusion of the Mid- and South Atlantic planning areas in the 

2019–2024 National OCS Oil and Gas Leasing Program. The commenter suggests the effects of a 

potential oil spill off the coast of South Carolina and other southeastern states could be devastating to 

their economy and environment. The commenter also states South Carolina’s coastline is not conducive 

to support oil and gas infrastructure. 

South Carolina House of Representatives, Lee Hewitt 

Document ID: BOEM-2017-0050-08700 

The commenter expresses opposition to the inclusion of the Atlantic OCS region in a future leasing 

program, specifically oil and gas leasing and related activities off the coast of South Carolina. The 

Summaries of Public Comments A-72 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

commenter states that constituents are opposed to offshore drilling due to the threat of a drilling disaster 

and the resulting environmental and economic harm it would bring to South Carolina. The commenter 

also argues that oil and gas drilling could negatively impact the tourism and commercial and recreational 

fishing industries, as well as marine life. 

South Carolina State Senate, George Campsen 

Document ID: BOEM-2017-0050-49810 

The commenter expresses opposition to oil and gas drilling off the coast of South Carolina. The 

commenter states that the associated industrial infrastructure that is necessary for offshore oil and gas 

drilling should not be allowed along the coast and that it would be incompatible with the current land uses 

that support tourism, real estate markets, and the ecosystem of the South Carolina coast. The commenter 

further argues that offshore development is not an economically viable energy source when new 

technologies and the lower market price of oil are taken into account. 

South Carolina House of Representatives, Bill Sandifer 

Document ID: BOEM-2017-0050-49808 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of the Atlantic OCS planning areas. The commenter states that prematurely excluding the Mid- and 

South-Atlantic planning areas from the program would deny citizens and businesses the opportunity to 

realize economic, societal, and environmental benefits. The commenter also states that developing these 

oil and gas resources will ensure U.S. energy security. 

South Carolina House of Representatives, Paul G. Campbell 

Document ID: BOEM-2017-0050-49809 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of the Atlantic OCS planning areas. The commenter states that prematurely excluding the Mid- and 

South-Atlantic planning areas from the program would deny citizens and businesses the opportunity to 

realize economic, societal, and environmental benefits. The commenter also states that developing these 

oil and gas resources will ensure U.S. energy security. 

Texas State House of Representatives, Dennis Paul 

Document ID: BOEM-2017-0050-51361 

The commenter expresses support for the development of a new leasing program and recommends the 

inclusion of all 26 OCS planning areas in the development of the DPP. The commenter states that 

excluding areas prematurely has the potential to negatively impact the Texas and U.S. economies and 

could harm efforts to ensure American energy security. The commenter further argues that the oil and gas 

industry provided the Federal Government with its largest source of revenue in 2014, highlighting the 

positive economic impact provided by offshore development of resources. 

Texas State Senate, Craig Estes 

Document ID: BOEM-2017-0050-48621 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 OCS planning areas in the development of the DPP. The commenter states that excluding areas 

prematurely has the potential to negatively impact the Texas and United States economies and could harm 

efforts to ensure American energy security. The commenter also argued that the rest of the Nation could 

Summaries of Public Comments A-73 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

share in the prosperity that Texas has experienced due to oil and gas drilling in the GOM if given greater 

access to these resources. 

Texas State Senate, Don Huffines 

Document ID: BOEM-2017-0050-18709 

The commenter expresses support for the development of a new leasing program and recommends the 

inclusion of all 26 OCS planning areas in the development of the DPP. The commenter states that 

excluding areas prematurely has the potential to negatively impact the economy of Texas and the greater 

United States. The commenter also stated that allowing private businesses the opportunity to explore and 

harness this untapped resource in the GOM would help the United States to become energy independent. 

Texas State House of Representatives, Brooks Landgraf 

Document ID: BOEM-2017-0050-49827 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of all 26 planning areas in the DPP. The commenter argues that offshore resource development provides 

significant economic impact for states, specifically Texas, citing the revenue and jobs created in the 

GOM. The commenter also states that economic gains from oil and gas development would trickle 

through the economy of the entire country 

Virginia Environment and Renewable Energy Caucus, Alfonso Lopez 

Document ID: BOEM-2017-0050-49642 

The commenter expresses opposition to oil and gas leasing in the Atlantic OCS, and argues that the 

current 2017–2022 Program should not be changed. The commenter states that the coastal communities 

of Virginia oppose offshore oil and gas development due to the potential negative impacts of oil spills on 

marine ecosystems, coastal communities, and economies. The commenter also states that the tourism and 

fishing industries would be at risk, and that Virginia is the largest seafood producer on the east coast. The 

commenter argues that offshore drilling could also come in conflict with military training and operations 

off the coastline. 

Virginia State Senate, Frank W. Wagner 

Document ID: BOEM-2017-0050-49835 

The commenter expresses support for the development of a new leasing program and urges the inclusion 

of the Atlantic OCS planning areas. The commenter states that prematurely excluding the Mid- and 

South-Atlantic planning areas from the program would deny citizens and businesses the opportunity to 

realize economic, societal, and environmental benefits. The commenter also states that developing these 

oil and gas resources will ensure the Nation’s energy security. 

Wyoming State Senate, Eli Bebout 

Document ID: BOEM-2017-0050-49839 

The commenter expresses support for the development of a new leasing program, and the inclusion of all 

26 OCS Planning Areas in the development of the DPP. The commenter states that excluding areas 

prematurely would undermine efforts to ensure American energy security and independence. The 

commenter argues that opening up access to these resources could generate jobs and government revenue. 

Summaries of Public Comments A-74 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

A.8 MEMBERS OF CONGRESS 

Thirty-Six Senators 

Document ID: BOEM-2017-0050-49693 

Thirty-six Senators state support for the development of a new oil and gas leasing program. The Senators 

state that preparation of a new program could help to ensure that prolific regions have not been arbitrarily 

excluded from competitive leasing. The Senators identify benefits to the economies of all the states, 

reduction in the Federal deficit, affordable energy, and strengthened national security as key reasons for 

pursuing a new program. 

Thirty Senators 

Document ID: BOEM-2017-0050-49692 

Thirty Senators express concern over the proposed revision of the 2017–2022 OCS Oil and Gas Leasing 

Program. The Senators state that the existing program correctly excluded areas from the leasing program 

that pose a significant environmental, economic, and cultural risk. Specifically identified were the Arctic 

Ocean, Atlantic Ocean, Pacific coast, and the Eastern GOM. 

One Hundred and Twenty Members of Congress 

Document ID: BOEM-2017-0050-51333 

One Hundred and twenty members of congress request BOEM encourage exploration and leasing in new 

OCS areas while maintaining investment in traditional offshore development areas. The commenters cite 

increased job creation, additional government revenue, and affordable and reliable energy supplies for 

consumers and manufacturing as key benefits to expanding development activities via a new National 

OCS Leasing Program. 

One Hundred and Three Members of Congress 

Document ID: BOEM-2017-0050-49696 

The commenters are in strong opposition to the Secretarial Order to move toward oil and gas exploration 

in the Atlantic Ocean and issuance of G&G permits. Offshore exploration, the first step of which is 

seismic testing, puts at risk coastal economies based on fishing, tourism, and recreation. Numerous 

studies show the detrimental impacts seismic airgun blasting has on fisheries and marine mammals, 

thereby affecting the catch anglers bring dockside and the revenue generated by related businesses. 

Seventy-Five Members of Congress 

Document ID: BOEM-2017-0050-49694 

Seventy-five members of Congress request BOEM adhere to the 2017–2022 Program and state opposition 

to oil and gas leasing in the U.S. Arctic. They further oppose BOEM considering areas previously 

excluded through executive order. The members of Congress also state that any potential leasing in the 

125 million acres of the Arctic previously preserved from future leasing would fall outside of legal 

authority. 

Sixty-Eight Members of Congress 

Document ID: BOEM-2017-0050-49695 

Sixty-eight members of Congress oppose oil and gas leasing in the Atlantic Ocean and Eastern GOM. 

The members of Congress indicate that more than 120 local governments have passed formal resolutions 

opposing oil and gas exploration and/or drilling in the Atlantic or Eastern Gulf, as well as local chambers 

Summaries of Public Comments A-75 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

of commerce, business associations and Fishery Management Councils. Additional stated reasons listed 

in opposition include detrimental effects for coastal businesses, fishing communities, tourism, and 

national security. 

Thirty-Nine Members of Congress 

Document ID: BOEM-2017-0050-49693 

Thirty-nine members of Congress oppose oil and gas leasing offshore California, Oregon, and 

Washington. Reasons listed in opposition include threats to ecosystems, the presence of endangered 

species, and potential detrimental effects to fishing and tourism. The commenters commend BOEM for 

its effort to lease and permit offshore wind energy projects along the coasts of all three states. 

Ten Members of Congress 

Document ID: BOEM-2017-0050-49691 

Ten members of Congress support development of a new National Leasing Program, stating that it is 

especially imperative to fully consider all OCS lands, including areas not part of the current 

2017–2022 Program. The members of Congress further state that, under the Obama Administration, 

significant strides were made by government and industry to advance the safety of offshore exploration 

and production, and that these should be employed to ensure worker and environmental safety while 

furthering goals for energy development. 

Senator Bill Nelson, Florida 

Document ID: BOEM-2017-0050-49748 

Senator Nelson emphasizes the importance of preserving the Eastern Gulf of Mexico Testing and 

Training Range. He indicates that the area of the OCS from the Military Mission Line to Florida’s Gulf 

coast is off limits by law to oil and gas preleasing, leasing, or any related activity per the 

2006 congressional moratorium. 

Congresswoman Kathy Castor, Florida 

Document ID: BOEM-2017-0050-49726 

The commenter requests BOEM exclude from consideration for leasing the Eastern GOM area. The 

commenter cites the economic and environmental value of the region as well as the importance of the area 

to national security and states that the risk of opening the area to leasing outweighs the potential benefits 

from oil and gas drilling. 

Congressman Donald McEachin, Virginia 

Document ID: BOEM-2017-0050-49528 

Congressman McEachin opposes oil and gas activities offshore of the Commonwealth of Virginia as well 

as the rest of the Atlantic and the Eastern GOM. The Congressman identifies potential problems for the 

Wallops Flight Facility, located in Accomack County, which a 2015 NASA report indicates would be 

majorly impacted and that the placement of “privately owned towers or other structures would severely 

constrain or eliminate existing and future Wallops range operations. The Congressman also identifies 

threats to coastal fisheries, tourism, and recreation related industries as key reasons. 

Summaries of Public Comments A-76 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Congressman Tom Rice, South Carolina 

Document ID: BOEM-2017-0050-49591 

The Congressman opposes opening waters off the coast of South Carolina for oil and gas production. The 

Congressman suggests that, given current market conditions, the economic benefits of OCS development 

offshore of South Carolina are no longer justified. 

A.9 TRIBES AND TRIBAL ORGANIZATIONS 

A.9.1 Alaska Region 

Arctic Iñupiat Offshore, LLC 

Document ID: BOEM-2017-0050-49611 

The commenter supports the inclusion of the Arctic OCS because of the positive economic impacts to the 

Iñupiat people and as a means to sustain the local North Slope economy. The commenter supports the 

deferral of areas important to subsistence that have been previously analyzed by BOEM, including the 

Kaktovik Whaling Area, Barrow Whaling Area, and Chukchi Sea 25-Mile Deferral Area and emphasizes 

the importance of continued collaboration with local Alaska Native stakeholders. 

Arctic Slope Regional Corporation 

Document ID: BOEM-2017-0050-49615 

The commenter supports the inclusion of planning areas in the GOM, Cook Inlet, Atlantic, and the Arctic 

OCS and emphasizes the importance of continued consultation with Alaska Native Claims Settlement Act 

Corporations as required by E.O. 13175. The commenter also emphasizes the importance of 

incorporation of traditional knowledge, subsistence resource preservation, existing mitigation measures, 

and community and economic benefits. 

Bering Sea Elders Group and Association of Village Council Presidents 

Document ID: BOEM-2017-0050-49709 

The commenter requests that BOEM exclude the following planning areas from consideration for 

inclusion in the 2019–2024 Program: Norton Sound, St. Matthew-Hall, Navarin Basin, Aleutian Basin, 

and St. George Basin. The commenter affirms the need for engagement in meaningful consultation and 

incorporation of indigenous knowledge in Agency decision making and identifies the areas in question as 

importance for subsistence use and commercial fisheries. Four reference attachments were included with 

the comment letter, pertaining to food security, ecosystem and climate change, and cultural traditions of 

the northern Bering Sea area as well as a resolution of the Association of Village Council Presidents dated 

October 19, 2016, that oil and gas or mineral activity or leasing should be prohibited. 

Bristol Bay Native Association 

Document ID: BOEM-2017-0050-00373 

The commenter requests the North Aleutian Basin Planning Area be excluded from the OCS leasing 

program. The commenter states that the Bristol Bay area within the North Aleutian Basin is home to a 

130-year-old commercial wild salmon fishery that supports 14,000 jobs and generates $500 million 

annually. The fishery is identified by the commenter as being of critical importance to the cultural and 

economic health of the region’s Aleut, Eskimo, and Athabascan peoples. 

Summaries of Public Comments A-77 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Kawerak, Inc. 

Document ID: BOEM-2017-0050-10073 

The commenter opposes the decision to change the current oil and gas management program for Federal 

waters offshore of Alaska and recommends the exclusion of the Hope, Norton, St. Mathew Hall, and 

Navarin Basin planning areas from any new programs. The commenter opposes any leasing activities in 

any of those planning areas. 

Native Village of Savoonga 

Document ID: BOEM-2017-0050-49840 

The commenter recommends BOEM exclude the Hope, Norton, St. Mathew-Hall, and Navarin Basin 

planning areas from any new National Program and does not support leasing activities in any of those 

planning areas. The commenter further encourages the incorporation of indigenous knowledge into 

BOEM’s decision making process and provides specific examples of actions BOEM can undertake to 

accomplish this through consultation, public meetings, and assessment of the effectiveness of outreach. 

Native Village of Shishmaref 

Document ID: BOEM-2017-0050-49787 

The commenter recommends BOEM exclude the Hope, Norton, St. Mathew-Hall, and Navarin Basin 

planning areas from any new National Program and does not support leasing activities in any of those 

planning areas. The commenter further encourages the incorporation of indigenous knowledge into 

BOEM’s decision making process and provides specific examples of actions BOEM can undertake to 

accomplish this through consultation, public meetings, and assessment of the effectiveness of outreach. 

Native Village of St. Michael, Theresa Kobuk 

Document ID: BOEM-2017-0050-51362 

The commenter requests the 2017–2022 Program be maintained for the 2019–2024 proposed lease 

program, specifically continuing to exclude the Hope, Norton, St. Mathew Hall, and Navarin Basin 

planning areas. The commenter discusses negatives impacts on low income and minority populations and 

potential consequences of increased ship traffic. The commenter also expresses continued support of 

E.O. 13754, which established the Northern Bering Sea Climate Resilience Area and requested BOEM 

consult tribes in their planning decisions. 

Olgoonik Corporation, The Alaska Native Village Corporation for Wainwright, Alaska 

Document ID: BOEM-2017-0050-49632 

The commenter supports the inclusion of the Chukchi and Beaufort Seas in any new Oil and Gas leasing 

program and commends Secretary Zinke’s stated goal to include “substantial public involvement and 

extensive analysis in all stages of the [Program] planning process.” The commenter also identifies the 

importance of outside business investment to incentivize the younger generation to remain in small 

communities such as Wainwright in the face of limited economic opportunities. 

A.9.2 Pacific Region 

Blue Lake Rancheria 

Document ID: BOEM-2017-0050-48910 

The commenter supports the exclusion of all areas currently excluded from the 2012–2017 Oil and Gas 

Leasing Program in perpetuity. The commenter further strongly opposes the leasing of any areas offshore 

Summaries of Public Comments A-78 January 2018 
 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Northern California for oil and gas drilling as well as the exploration or development in any sensitive 

marine environment in U.S. waters. 

Confederated Tribes of Coos, Lower Umpqua & Siuslaw Indians 

Document ID: BOEM-2017-0050-49616 

The commenter requests that BOEM exclude from consideration for leasing the Pacific OCS, especially 

the portion of the OCS off of the coast of Oregon. The commenter provides additional context and 

information concerning their history of using the coastal environment, BOEM’s consultation and trust 

obligations, safety concerns, and potential impacts on cultural resources. 

Coquille Indian Tribe 

Document ID: BOEM-2017-0050-49729 

The commenter identifies the importance of tourism and fishing along the southern Oregon coast and 

expresses concern regarding the potential for oil and gas leasing in the areas offshore of Coos and Curry 

Counties. The commenter identifies the importance formal government-to-government consultation and 

requests BOEM initiate consultation regarding the potential for OCS oil and gas leasing. 

Federated Indians of Graton Rancheria 

Document ID: BOEM-2017-0050-49746 

The commenter expresses concern with the potential for harm to the marine environment that could occur 

as the result of proposed leasing activities. The commenter emphasizes the need for BOEM to consider 

the effects on traditional cultural properties and species as well as how communities could be impacted by 

effects to coastal resources. 

Habematolel Pomo of Upper Lake Tribe 

Document ID: BOEM-2017-0050-49756 

The commenter supports the exclusion of all areas currently excluded from the 2012–2017 Oil and Gas 

Leasing Program in perpetuity. The commenter further strongly opposes the leasing of any areas offshore 

Northern California for oil and gas drilling as well as the exploration or development in any sensitive 

marine environment in U.S. waters. 

Kashia Band of Pomo Indians of the Stewart’s Point Rancheria 

Document ID: BOEM-2017-0050-50671 

The commenter strongly opposes oil and gas activities offshore and specifically requests the area from 

Duncan’s Landing to the mouth of the Gualala River (in California) be excluded from consideration for 

leasing. Additionally, the commenter provides a list of specific topic areas BOEM should consider as it 

analyzes the potential impacts of oil and gas activity in the offshore. These include impacts on 

environmental resources, subsistence activities, and recommendations for how BOEM could mitigate the 

negative impacts associated with potential spills. 

Makah Tribe 

Document ID: BOEM-2017-0050-49650 

The commenter requests the Pacific OSC region be excluded from the National OCS DPP, as these 

activities pose potential risk to Pacific Ocean ecosystems and treated reserved resources. The commenter 

also requests BOEM include comprehensive risk assessment and response plans for all regional planning 

areas being considered in the new program, especially the Pacific and Arctic regions. 

Summaries of Public Comments A-79 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Makah Tribal Council 

Document ID: BOEM-2017-0050-49773 

The formal position of the Makah Tribal Council is to not include the Pacific OCS region in the National 

OCS DPP and to oppose any oil and gas exploration or leasing activity off the coast. The commenter 

identifies a traditional use area and provides treaty information. The commenter further recommends 

BOEM include a comprehensive risk assessment and response plan for all regional planning areas 

considered in the program. 

Northern California Tribal Chairmen’s Association 

Document ID: BOEM-2017-0050-49773 

The commenter strongly opposes the leasing of any areas offshore of Northern California for oil and gas 

drilling. The commenter also opposes exploration or development activities in any sensitive marine 

environment in Federal waters and emphasizes that these comments do not constitute required 

government-to-government consultation that must occur individually with all affected sovereign Tribal 

governments before leasing can occur. 

Quileute Tribal Council 

Document ID: BOEM-2017-0050-51348 

The commenter requests that BOEM acknowledge treaty obligations between the Federal Government 

and treaty tribes of the northwest inclusive of the Quileute Tribe. The commenter opposes oil and gas 

development activities including leasing and recommends BOEM make funds available to improve 

understanding of marine productivity and environmental sensitivity. 

San Luis Rey Band of Mission Indians 

Document ID: BOEM-2017-0050-49537 

The commenter supports keeping all areas that are currently excluded from the 2012–2017 Oil and Gas 

Leasing Program as perpetual exclusions. The commenter further strongly opposes the leasing of any 

areas offshore of Northern, Central, and Southern California for oil and gas drilling and as well as other 

sensitive marine environments in U.S. waters. 

Santa Ynez Band of Chumash Indians 

Document ID: BOEM-2017-0050-49551 

The commenter opposes all oil and gas leasing along the central coast of California and recommends 

BOEM exclude from consideration for leasing in perpetuity all areas that were excluded in the 

2012–2017 Program. 

Scotts Valley Band of Pomo Indians 

Document ID: BOEM-2017-0050-49644 

The commenter supports keeping of all the areas currently excluded in the 2012–2017 Oil and Gas 

Leasing Program as perpetual exclusions. The commenter further opposes any exploration or 

development in any sensitive marine environment in U.S. waters. 

A.9.3 Gulf of Mexico Region 

No comment letters from Gulf of Mexico Region tribes or tribal organizations were submitted in response 

to the RFI. 

Summaries of Public Comments A-80 January 2018 
 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

A.9.4 Atlantic Region 

Gullah/Geechee Nation 

Document ID: BOEM-2017-0050-28229 

The commenter states opposition to all offshore oil and gas exploration off the coast of North Carolina, 

South Carolina, Georgia, and Florida and to seismic surveys using airguns. The commenter includes for 

additional reference a resolution dated October 1, 2015, which was submitted to BOEM as part of the 

previous scoping process for the 2017–2022 National Program. The commenter requests that all planning 

areas in the Atlantic Ocean be excluded. 

A.10 FORM LETTER CAMPAIGNS 

Below is a list of form letter campaigns received during the RFI comment period. The list includes the 

campaigns, including the originating organization (if identified), the total number of submissions in the 

campaign, and a brief summary of the information provided as part of the campaign. 

Form Letter Document ID Organization/ 

Commenter Name 

Total 

Submissions 

in Campaign 

Summary of Submission Letter 

BOEM-2017-0050-51163 Friends of the 

Earth (Megan 

Coglianese) 

35,922 • Proposed Program would put 

marine ecosystems and coastal 

economies and communities at 

risk. 

• The Pacific Coast has been 

offlimits to drilling since the 

1980s. 

• The proposed program would 

solely benefit oil companies. 

BOEM-2017-0050-51164 CREDO 89,809 • Oil and gas drilling in the Gulf 

of Mexico threatens oceans and 

coastal regions with dangerous 

oil spills and worsens the 

climate crisis. 

BOEM-2017-0050-51364 Friends of the 

Earth 

36,247 • The current program protects 

certain areas of the OCS from 

oil drilling activities. 

• Rolling back these protections 

solely benefits oil companies. 

• The proposed program puts 

marine ecosystems and coastal 

economies and communities at 

risk. 

Summaries of Public Comments A-81 January 2018 
 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Form Letter Document ID Organization/ 

Commenter Name 

Total 

Submissions 

in Campaign 

Summary of Submission Letter 

BOEM-2017-0050-51175 Sierra Club 78,036 • Opposes oil and gas leasing in 

the Arctic, Atlantic, and Pacific 

planning regions. 

• Public opposition to drilling in 

these regions was very strong 

during the previous public 

comment period. 

BOEM-2017-0050-51176 Center for 

Biological 

Diversity 

24,751 • Opposes offshore oil and gas 

leasing in any and all oceans. 

• Offshore drilling threatens 

marine wildlife and coastal 

communities, and exacerbates 

climate change. 

• Defense experts warn that 

drilling threatens national 

security and impedes military 

readiness. 

BOEM-2017-0050-51177 Ocean 

Conservancy 

16,757 • Opposes expanding oil and gas 

leasing to additional planning 

areas. 

• An oil spill could cause severe 

impacts to the economies of 

coastal communities, disrupt 

recreational and commercial 

fishing, and harm marine 

wildlife. 

• Planning areas under 

consideration lack necessary 

infrastructure. 

BOEM-2017-0050-51178 Consumer 

Energy Alliance 

15,263 • Supports including all unleased 

areas in the draft leasing 

program. 

• Developing these resources will 

provide jobs and economic 

growth. 

• Expanding oil and gas 

developments will lessen 

dependence on foreign energy 

resources. 

Summaries of Public Comments A-82 January 2018 
 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Form Letter Document ID Organization/ 

Commenter Name 

Total 

Submissions 

in Campaign 

Summary of Submission Letter 

BOEM-2017-0050-51174 Food and Water 

Watch 

17,110 • Opposes offshore drilling off 

the coast of Florida. 

• An oil spill could hurt the 

environment, economy, and 

tourism and fishing industries. 

BOEM-2017-0050-51187 Audubon 

California 

5,786 • Opposed to any new oil and gas 

leasing in the Pacific OCS. 

• Energy conservation and 

renewable energy sources will 

benefit consumers. 

• California has experienced the 

consequences of oil spills in the 

past. 

BOEM-2017-0050-51184 Oceana 29,268 • Opposes lease sales in the 

Atlantic, Pacific, and Arctic 

Oceans and the Eastern Gulf of 

Mexico. 

• The unlikely benefits of 

offshore drilling do not 

outweigh the risks. 

BOEM-2017-0050-51185 Oceana 95 • Oppose lease sales in the 

Atlantic, Pacific, and Arctic 

Oceans and the Eastern Gulf of 

Mexico. 

• Offshore drilling will put 

marine environments, 

communities and industries at 

risk. 

BOEM-2017-0050-51173 Wildlife 

Conservation 

Society 

14,205 • Requests that BOEM protects 

marine life and considers full 

scope of effects of offshore 

drilling, specifically in the 

Atlantic Ocean. 

BOEM-2017-0050-51170 Conservation 

Voter of South 

Carolina 

71 • Opposes offshore drilling in the 

Atlantic OCS and altering the 

current program. 

BOEM-2017-0050-51165 Alaska 

Wilderness 

League 

19,385 • Opposes offshore drilling in the 

ocean, specifically the Arctic. 

• Opposes altering the current 

program. 

Summaries of Public Comments A-83 January 2018 
 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Form Letter Document ID Organization/ 

Commenter Name 

Total 

Submissions 

in Campaign 

Summary of Submission Letter 

BOEM-2017-0050-51363 NRDC 43,397 • Opposes offshore drilling in the 

Arctic and Atlantic Oceans. 

• Offshore drilling threatens 

marine life and puts coastal 

communities at risk. 

BOEM-2017-0050-

51166,51167,51168,5116 

9 

The Pew 

Charitable Trusts 

11,528 • Opposes offshore drilling in the 

Arctic OCS. 

• Offshore areas contribute to the 

function of the larger ecosystem 

and should not be put at risk. 

BOEM-2017-0050-51172 Surfrider 

Foundation 

2,448 • Opposes offshore drilling in the 

Pacific and Atlantic OCS. 

• Expanded access poses a threat 

to natural resources, the 

economy, and way of life. 

BOEM-2017-0050-51183 Veterans 1,676 • Opposes the expansion of 

offshore drilling in the OCS. 

• New drilling could harm 

military readiness. 

• The Eastern GOM is 

particularly critical to military 

training and testing activities. 

BOEM-2017-0050-51180 World Wildlife 

Fund 

80,497 • Opposes oil and gas leasing in 

the Beaufort and Chukchi Seas. 

• Offshore drilling poses risks to 

the environment and wildlife. 

BOEM-2017-0050-51181 Environment 

America 

6,392 • Opposes offshore drilling off 

the coasts of Alaska and 

Florida. 

• Oceans are home to stunning 

wildlife and beaches. 

BOEM-2017-0050-51189 Earthjustice 27,184 • Opposes expanding oil and gas 

leasing and changing the 

current program. 

• Offshore drilling is dangerous 

and oil spills are inevitable. 

BOEM-2017-0050-51190 Oil Change 

International 

1,274 • Opposes opening the Atlantic, 

Arctic, Pacific and GOM to 

additional oil and gas drilling. 

• Offshore drilling puts coastal 

communities and economies at 

risk. 

Summaries of Public Comments A-84 January 2018 
 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Form Letter Document ID Organization/ 

Commenter Name 

Total 

Submissions 

in Campaign 

Summary of Submission Letter 

BOEM-2017-0050-51188 Save Our Sea NC 169 • Opposes seismic airgun blasting 

and offshore drilling in the 

Atlantic OCS. 

BOEM-2017-0050-51171 Sierra ClubVirginia Chapter 955 • Opposes offshore drilling in the 

Atlantic OCS, specifically off 

the coast of Virginia. 

• Offshore drilling poses risks to 

the tourism and aquaculture 

industries in Virginia. 

BOEM-2017-0050-51179 Southern 

Alliance for 

Clean Energy 

193 • Offshore drilling and seismic 

blasting are not appropriate for 

the Atlantic coast. 

• Offshore drilling and seismic 

blasting jeopardize the 

environment but also our 

thriving coastal tourism 

economy. 

BOEM-2017-0050-51199 Virginia 

Petroleum 

Council 

97 • Domestic energy development, 

including offshore oil and gas in 

the GOM, and expanded access 

into new areas of the Alaska, 

Atlantic and GOM, would 

benefit the United States and its 

citizens and help keep U.S. 

energy renaissance going. 

BOEM-2017-0050-51182 Greenpeace USA 1,171 • Prohibit new drilling on any 

U.S. coast in an effort to reduce 

use of fossil fuels and slow 

climate change. 

• Millions of Americans have 

expressed opposition and 

concern about offshore drilling. 

• Coastal communities and 

governors have urged protection 

of livelihoods rooted in tourism, 

fishing, and other coastal 

activities. 

• Coastal communities will be 

affected by seismic testing and 

oil spills. 

Summaries of Public Comments A-85 January 2018 
 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Form Letter Document ID Organization/ 

Commenter Name 

Total 

Submissions 

in Campaign 

Summary of Submission Letter 

BOEM-2017-0050-51195 North Carolina 

League of 

Conservation 

Voters 

339 • Offshore oil and gas drilling 

would put local communities 

and industries that rely on clean 

waters and unspoiled beaches at 

risk. 

• Oil spills will devastate NC’s 

fisheries, tourism and 

recreation, and cost thousands 

of jobs and billions in lost 

revenue. 

BOEM-2017-0050-51194 North Carolina 

Conservation 

Network 

2,252 • Requests removal of North 

Carolina’s coast from any 

future plans for offshore 

drilling. 

• Oil and gas drilling threatens 

existing businesses that 

contribute billions of dollars in 

revenue and provide good jobs 

to coastal residents. 

BOEM-2017-0050-51200 Climate Writers 5 • Expressed concern about 

climate change. 

BOEM-2017-0050-51196 Joe Jansen 100,354 • Domestic energy independence 

will create jobs, grow the 

economy, and increase energy 

security. 

• Supports leasing in Alaska, 

EGOM, and Atlantic. 

BOEM-2017-0050-51356 Virginia League 

of Conservation 

Voters 

3,649 • Opposes offshore drilling in the 

Atlantic. 

• Oil and gas drilling risks the 

health of communities and 

industries that rely on clean 

waters and unspoiled beaches. 

• Oil spills could threaten 

Virginia’s fisheries, tourism and 

recreation industries. 

BOEM-2017-0050-51191 Campaign A 22,000 • Supports leasing in Alaska, 

EGOM, and Atlantic. 

• Domestic energy independence 

will create jobs, grow the 

economy, and increase energy 

security. 

Summaries of Public Comments A-86 January 2018 
 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Form Letter Document ID Organization/ 

Commenter Name 

Total 

Submissions 

in Campaign 

Summary of Submission Letter 

BOEM-2017-0050-51198 Environmental 

Action 

53,192 • Opposes opening the Arctic to 

oil and gas drilling. 

• Opposes review of possible new 

drilling sites off the Atlantic 

Coast. 

• Expressed strong opposition to 

seismic testing and offshore 

drilling. 

BOEM-2017-0050-51192 Campaign B 140 • Requests BOEM deny all 

seismic testing permit requests 

for the Atlantic. 

• Seismic airgun blasting can 

result in displaced fish, reduced 

catch rates, and disrupts vital 

feeding and breeding behaviors 

in marine mammals. 

BOEM-2017-0050-00077 David Bennett 8,174 • Opposes opening protected 

areas in the Arctic, Atlantic, and 

Pacific. 

• exposing our coastal 

communities to hazardous oil 

and gas drilling directly runs 

counter to the BOEM’s mission. 

• Opening up these fragile 

ecosystems to drilling 

jeopardizes our coastal 

economies, marine wildlife, and 

climate. 

BOEM-2017-0050-08723 Kristen Brown 30,302 • Opposes offshore drilling in the 

Atlantic. 

• Opening the Atlantic to oil and 

gas drilling jeopardizes future 

for short-term industry profits. 

BOEM-2017-0050-0097 Peter Smith 6,613 • There is no way to responsibly 

drill in the Arctic. 

• Supports continued exclusion of 

the Beaufort and Chukchi seas. 

• Opposes any new lease sales 

under the revised program. 

BOEM-2017-0050-31745 Lacey Hicks 20,297 • Opposes oil and gas drilling in 

all U.S. coastal waters. 

• Drilling is risky to coastal 

residents and jeopardizes 

Summaries of Public Comments A-87 January 2018 
 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Form Letter Document ID Organization/ 

Commenter Name 

Total 

Submissions 

in Campaign 

Summary of Submission Letter 

critical ecosystems. 

• Drilling increases the threat of 

devastating oil spills, all while 

driving climate change and 

threatening our clean energy 

future. 

BOEM-2017-0050-19503 Shane Farnor 4,935 • Opposes new oil and gas 

development in the Atlantic and 

Pacific. 

• National parks should be 

protected from potential spills 

or harassment. 

BOEM-2017-0050-29731 Elizabeth Slikas 10 • Opposes any expansion of 

offshore leasing for oil and gas 

drilling. 

• Opening up more areas to 

offshore drilling would have 

devastating impacts on coastal 

communities and climate. 

BOEM-2017-0050-08345 Greater Port 

Arthur Chamber 

of Commerce, 

William McCoy 

32 • Expressed support for 

developing a new leasing 

program. 

• Urged the inclusion of all 

26 OCS planning areas 

including GOM. 

BOEM-2017-0050-51197 NCLCV 103 • Oil and gas drilling risks the 

health of communities and 

industries that rely on clean 

waters and unspoiled beaches. 

• Oil spills could threaten 

Virginia’s fisheries, tourism and 

recreation industries. 

BOEM-2017-0050-51193 Campaign C 23 • No seismic testing or offshore 

drilling in Atlantic. 

• Activities can ruin the 

economy, coastline, ecology 

and way of life for SC residents. 

BOEM-2017-0050-08612 Southern 

Chemical 

Corporation 

9 • Expressed support for 

developing a new leasing 

program. 

• Urged the inclusion of all 

26 OCS planning areas. 

Summaries of Public Comments A-88 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

Form Letter Document ID Organization/ 

Commenter Name 

Total 

Submissions 

in Campaign 

Summary of Submission Letter 

BOEM-2017-0050-50540 Thomas Jefferson 

Institute for 

Public Policy, et 

al. 

98 • United States should take full 

advantage of the potential 

benefits that continued and 

expanded offshore exploration 

and production can bring to the 

United States and its citizens. 

• Supports expanded access into 

new areas of the GOM, Arctic, 

and Atlantic. 

A.11 GENERAL PUBLIC 

A.11.1 General Comments from Individuals Not Specific to OCS Program Areas 

Approximately 815,385 submissions were received from individuals, of which approximately 

812,165 were submitted as part of form letter campaigns. Approximately 115,850 (or 14 percent) of the 

form letter submissions from individuals express general support for the 2019–2024 Program, while 

approximately 396,431 (or 49 percent) of the form letter submissions from individuals express general 

opposition. Of the unique submissions received from individuals, numerous submissions provide general 

comments with regard to the National Program and impacts on the environment, tourism, economy, and 

increase in the nation’s energy dependence. 

Numerous individuals express general support for BOEM’s offshore leasing program, suggesting that 

continued and expanded exploration and development of U.S. resources, including in areas like the 

Atlantic, GOM, Pacific, and Alaska, will lead to greater domestic offshore oil and natural gas production, 

job creation, economic prosperity, and increased energy security for the Nation and local communities. 

Numerous commenters express support for an energy policy that allows for more leasing, exploration, and 

development of potential U.S. offshore oil and natural gas resources. One commenter states that 

developing energy in the U.S. under existing stringent regulatory standards would safeguard the 

environment by lessening dependence on energy from other nations with less rigorous protections. 

Others explain that excluding regions from leasing consideration at the outset, and in the absence of 

critical environmental analysis, would be premature and harm efforts to ensure American energy security. 

Numerous individuals express opposition to developing a new offshore leasing program, explaining that 

new offshore drilling jeopardizes fragile coastal marine ecosystems and coastal economies and put 

communities at risk. Several commenters urge BOEM to maintain current protections and exclude the 

Atlantic, Pacific, and Arctic Oceans and the Eastern GOM and all national marine protected areas from 

the DPP. Commenters state that increasing coastal drilling would go against the millions of Americans 

who have previously voiced their desire to protect public natural resources. Similarly, commenters 

express disappointment in BOEM’s decision to reopen the offshore drilling planning process prior to the 

expiration of the current 2017–2022 Program in which millions of Americans expressed their support for 

permanent protections to the Arctic, Atlantic, and Pacific oceans. Commenters also note that local and 

Summaries of Public Comments A-89 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

USDOI 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program BOEM 

state government and industry interest in offshore drilling and/or seismic testing has decreased, citing the 

coastal city resolutions against offshore drilling and/or seismic testing, and Shell’s decision to back down 

on plans to pursue oil in the Artic because of strong public opposition, costs, and physical risks and 

challenges. 

Commenters in opposition to offshore oil and gas development also cite environmental concerns 

including oil spills, leaks, and air and water pollution resulting in negative effects on public health, 

marine resources, and the impacts on recreation and tourism industries. Some commenters express 

concern for the effects that noise from seismic testing could have on marine wildlife. Several 

commenters anticipate the negative impacts listed above would worsen if offshore drilling is expanded to 

additional areas. 

Several suggest that because offshore drilling is inherently dangerous, additional devastating oil spills are 

inevitable. Increased storm severity in the face of climate change will increase the risks of oil spills, 

accidents, and other environmental harms associated with offshore drilling. Many commenters are 

concerned about the impact a loss of well control could have and on coastal economics, commercial and 

recreational fisheries, beaches and shorelines as well as birds, fish, and marine mammals, and suggest that 

impacts from offshore oil spills can last for decades. Many individuals express concern about the 

consequences to the tourism industry from an oil spill. Some commenters state that an oil spill would 

pollute beaches, devastate tourism and recreation, and could result in a loss of industry jobs in coastal 

communities. Some commenters suggest that many planning areas under consideration for new leasing 

lack the infrastructure necessary to support offshore oil and gas operations, including remote and 

dangerous waters off the coast of Alaska, including the Bering Sea and Arctic Ocean. 

Several commenters suggest oil and gas drilling would contribute to carbon pollution and would hold 

back the Nation’s transition to clean energies. Commenters encourage the use of alternative energy 

sources such as wind or solar to move beyond dependence on fossil fuels. Some commenters state that 

exposing coastal communities to hazardous oil and gas drilling runs counter to BOEM’s mission and duty 

to the American people. 

A.11.2 Comments from Individuals Specific to Program Areas 

Many individuals provided comments on environmental concerns specific to the Alaska, Atlantic, Pacific 

and GOM planning areas. Individuals urge BOEM to reject the plan to reopen the Arctic and Atlantic 

oceans, stating that expanding offshore drilling threatens marine life and puts coastal communities at risk. 

Individuals state that offshore drilling in the Atlantic could cause injury or death to marine wildlife 

including whales, sea turtles, and dolphins, and endangered and threatened species like the North Atlantic 

right whale and the hawksbill and loggerhead sea turtles that utilized the Atlantic Ocean for habitat and 

migration routes. Individuals also express concern that harmful seismic airgun surveys in the Atlantic 

Ocean would threaten species in the area. Some commenters request that BOEM deny all seismic testing 

permit requests for the Atlantic, noting that peer-reviewed studies, including those conducted by the 

Department of the Interior, concluded that seismic airgun blasting results in displacement of fish, reduced 

catch rates of some fish species, and disrupts the feeding and breeding behaviors in marine mammals. 

Commenters also suggest that opening new drilling sites off the Atlantic coast would prolong the 

country’s dependence on fossil fuels at the expense of environment. 

Summaries of Public Comments A-90 January 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Individuals express concern that oil spills in the Arctic, Atlantic, Pacific, and GOM would impact wildlife 

refuges, marine protected areas, endangered and protected species, critical habitat, and other marine 

wildlife and fish populations, many of which have not recovered from past oil spill events or are under 

stress from other activities. Other individuals express concern about effects on marine life in the Arctic, 

Atlantic, and GOM planning areas due to the toxicity of oil. Commenters also note that opening the 

Atlantic to oil and gas drilling could jeopardize short-term industry projects if an oil spill were to occur. 

The commenters note the millions of comments received from individuals, small business owners, 

tourism authorities, anglers, and elected officials requested offshore drilling in the Atlantic be removed 

until 2022. Similarly, commenters request the 46 national parks off the Atlantic and Pacific coasts be 

protected from oil spills, noting visitors to these parks contribute billions of dollars to local economies, 

support thousands of jobs, and protect marine wildlife. In the Atlantic, commenters specifically discuss 

concerns for the coasts of Florida, Georgia, South Carolina, North Carolina, Virginia, and New Jersey, 

and request excluding these coasts from any future oil and gas development. Commenters request that 

BOEM not allow risky oil and gas drilling in highly sensitive Arctic waters without essential scientific 

information and an effective plan to clean up an oil spill in the Arctic’s extreme conditions. Some 

commenters suggest that drilling in the Arctic will release black carbon pollution directly onto Arctic ice, 

which will accelerate melting and put sea ice-dependent species at even greater risk. Commenters discuss 

the impacts of the 1969 oil spill in Santa Barbara California and the resulting implementation of 

restrictions. 

A few commenters discuss the DOD restrictions on offshore drilling due to incompatibility with the 

maintenance of military readiness, military activities, and safety concerns. According to a commenter, 

the DOD had previously determined that no oil and gas activity could occur in portions of the Atlantic. 

Another commenter, who requests that BOEM maintain the moratorium on oil and gas activities in the 

GOM beyond 2022, notes that the Eastern GOM Planning Area is also critical to the DOD due to the 

number of military testing and training activities conducted there. Another commenter suggests that the 

U.S. military restricts drilling in the Pacific Ocean, stating that 36 percent of the Southern California 

Planning Area faces site-specific stipulations due to military conflicts. 

Several commenters, however, urge BOEM to include all offshore planning areas in the initial phase of 

the 2019-2024 Program. These commenters reference several benefits of oil and gas development, 

including how the billions of barrels of oil equivalent in the undiscovered areas could contribute to the 

Nation’s oil and natural gas needs for decades. Commenters cite the economic gains experienced by 

GOM states and coastal communities with the increase in GOM offshore oil and gas activity, including an 

increase in Gross Domestic Product and public revenue. Commenters also state that new offshore 

development will allow America to sustain an energy renaissance and preserve the Nation’s energy 

security. 

Summaries of Public Comments A-91 January 2018 
 

APPENDIX B: ECONOMIC ANALYSIS METHODOLOGY FOR THE 

2019–2024 NATIONAL OUTER CONTINENTAL SHELF 

OIL AND GAS LEASING 

DRAFT PROPOSED PROGRAM 

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Abbreviations and Acronyms 

AEO Annual Energy Outlook 

bbl barrels of oil 

BOE barrel of oil equivalent 

BOEM Bureau of Ocean Energy Management 

Btu British thermal units 

CO2 carbon dioxide 

CO carbon monoxide 

DPP 2019–2024 National OCS Oil and Gas Leasing Draft Proposed Program 

EIS environmental impact statement 

GHG greenhouse gas 

GOM Gulf of Mexico 

mcf thousand cubic feet 

NEV net economic value 

NOx oxides of nitrogen 

NSV net social value 

OCS Outer Continental Shelf 

OECM Offshore Environmental Cost Model 

PFP Proposed Final Program 

PM2.5 Particulate matter with a diameter equal to or less than 2.5 microns 

PM10 Particulate matter with a diameter equal to or less than 10 microns 

SO2 sulfur dioxide 

USEPA U.S. Environmental Protection Agency 

USGS U.S. Geological Survey 

VOC volatile organic compound 

WEB3 When Exploration Begins, version 3 

Acronyms and Abbreviations B-2 January 2018 
 

 

 

USDOI Economic Analysis Methodology for the 2019–2024 National OCS Oil and Gas Leasing Program BOEM

Table of Contents 

Chapter 1 Net Social Value Analysis Methodology.............................................................................................B-4 

1.1 Introduction..............................................................................................................................................B-4 

1.2 NSV Step 1: Gross Revenue ...................................................................................................................B-6 

1.2.1 Resource Assumptions.........................................................................................................................B-6 

1.2.2 Price-Level Assumptions.....................................................................................................................B-6 

1.3 NSV Step 2: Net Economic Value ..........................................................................................................B-7 

1.4 NSV Step 3: Net Social Value ................................................................................................................B-8 

1.5 Non-monetized Impacts .........................................................................................................................B-10 

1.5.1 Non-monetized Costs.........................................................................................................................B-10 

1.5.2 Non-monetized Benefits ....................................................................................................................B-15 

Chapter 2 Fair Market Value Analysis: WEB3 Methodology...........................................................................B-17 

2.1 WEB3 Calculations................................................................................................................................B-17 

2.2 Hurdle Price Assumptions......................................................................................................................B-18 

2.2.1 Resource Assumptions.......................................................................................................................B-18 

2.2.2 Price Assumptions .............................................................................................................................B-19 

2.2.3 Private Cost Assumptions..................................................................................................................B-20 

2.2.4 Environmental and Social Cost Assumptions....................................................................................B-20 

Chapter 3 References..........................................................................................................................................B-21 

List of Tables 

Table B-1: Price Cases .............................................................................................................................................B-6 

Table B-2: Greenhouse Gas Emissions ..................................................................................................................B-11 

List of Figures 

Figure B-1: Components of the DPP Net Social Value Analysis .............................................................................B-4 

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Chapter 1 Net Social Value Analysis Methodology 

1.1 INTRODUCTION 

The purpose of the net social value (NSV) analysis conducted for the Draft Proposed Program (DPP) 

analysis to provide a relative value ranking of planning areas to assist the Secretary in making the initial 

National OCS Program decision. This includes providing the Secretary with a quantitative metric to 

compare planning areas based on available resources and the relative private, environmental, and social 

costs of extracting those resources. The NSV analysis at this stage is an appraisal of the value of each 

planning area. For the upcoming Proposed Program and Proposed Final Program (PFP) analyses, the 

analysis uses anticipated production rather than all available undiscovered economically recoverable 

resources (UERR). Anticipated production reflects more refined assumptions of exploration and 

development activities and associated production. These later stage analyses also account for other 

factors that are important in evaluating specific program decisions, such as rig availability, demand 

conditions, supply-induced price changes on domestic consumers and producers, and the impacts of 

energy substitutes that would compensate for forgone OCS production in the absence of lease sales under 

an approved National OCS Program. 

The analysis presented here is based on an evaluation of all resources estimated to exist in each planning 

area. The analysis considers both the value of these resources and the private, environmental, and social 

costs necessary to explore for, develop, produce, and transport these resources. Figure B-1 summarizes 

the components of the NSV analysis. 

Figure B-1: Components of the DPP Net Social Value Analysis 

Key: UERR=undiscovered economically recoverable resources. 

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The NSV of OCS oil and gas resources is calculated by subtracting both the private and environmental 

and social costs of exploration, development, production, and transportation from the gross revenue of all 

UERR in each planning area. The estimates of benefits and costs presented in the NSV analysis were 

obtained using the same basic methods as those used for the analyses performed for the previous National 

OCS Programs. The timing assumptions, described in the next paragraph, are the same as those used in 

the 2017–2022 DPP analysis. 

The NSV for the 2019–2024 DPP analysis is calculated through a scenario in which all currently available 

resources are leased during the initial year of the new National OCS Program (2019). This scenario 

avoids a circuitous logic whereby the analysis would prematurely presume the size, timing, and location 

decisions that are to be based, in part, on that same analysis, and so, cannot be made until that analysis is 

complete. This approach is consistent with the Court’s opinion in California II (see Section 2.7 in the 

DPP) that it was reasonable to use a methodology that avoided that circuitous logic for the ranking of 

planning areas required by the OCS Lands Act at this stage of the planning process. In this scenario, the 

resources are discovered and produced at an orderly and expeditious rate typical of each planning area, 

assuming there are no special constraints that might result from a Secretarial decision on size, timing, and 

location of lease sales. Each region has specific timing assumptions assigned to it, based on 

characteristics in that region (e.g., development and production in the Alaska planning areas is expected 

to start later than production from Gulf of Mexico [GOM] planning areas). Other than considering 

regional characteristics, there are no binding constraints on the pace of exploration and production. 

Therefore, it is assumed that as many rigs are available as are necessary for drilling and there are no 

worker shortages. 

When the next round of analyses is prepared for the Proposed Program, the net social benefits analysis 

will focus only on the planning areas and portions of planning areas (i.e., the program areas) identified for 

leasing consideration in the DPP decision (see Part I of the DPP). The analysis will only include 

economic benefit and cost estimates associated with those resources anticipated to be discovered and 

produced as a result of the new National OCS Program (as opposed to total available resources). The 

different resource assumptions used at each stage of the National OCS Program are illustrated in 

Figure 5-

8 in the DPP. Further, the Proposed Program analysis will include an estimate of consumer 

surplus benefits for each program area and will subtract environmental and social costs associated with 

the energy market substitutes should a new National OCS Program not be approved. 

The NSV analysis is approached from a national perspective, which provides the Secretary with a clear 

picture of the overall balance of benefits and costs tied to the total resources available in each planning 

area. In addition to this national approach to costs and benefits, another aspect of social value involves 

comparison of the benefits of incremental employment, labor income, and other such factors associated 

with OCS oil and gas exploration and development activity. This approach is more appropriate when 

considering impacts from the local or regional perspective and is used in the analysis on equitable sharing 

of developmental benefits and environmental risks covered in Chapter 8 of the DPP. 

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1.2 NSV STEP 1: GROSS REVENUE 

The NSV analysis begins with the calculation of the gross revenue from the production of all UERR in 

each of the 26 OCS planning areas. Gross revenue equals the production of each resource multiplied by 

the assumed price level (see Figure B-1). 

1.2.1 Resource Assumptions 

The DPP analysis assumes that all unleased UERR on the OCS as of July 2019 are leased in the first year 

of the National OCS Program and produced throughout the life of the National OCS Program. The total 

UERR used for the NSV calculation are shown in the DPP in Table 5-1 in Section 5.3.6, Unleased 

Undiscovered Economically Recoverable Resources. 

1.2.2 Price-Level Assumptions 

Leasing from the 2019–2024 Program will stimulate exploration, development, and production activity 

for decades, over which time oil and natural gas prices could fluctuate drastically. Historical oil price 

volatility has shown that unanticipated market and political events, new technologies, weather, 

geopolitical unrest, or economic changes can cause energy price paths to deviate considerably from even 

the most respected forecasts. Moreover, use of a trend forecast or fluctuating prices in the NSV analysis 

would render it difficult to separate out the effects of assumed price changes and their timing from the 

resource and cost differences in planning areas on the measures of NSV. Given the extreme uncertainty 

surrounding oil and natural gas prices over the life of leases sold during this National OCS Program, the 

analysis includes resource and net benefits evaluated at each level of three sets of real price cases shown 

in Table B-1. These price cases are consistent with the Bureau of Ocean Energy Management’s (BOEM) 

Assessment of Undiscovered Technically Recoverable Oil and Gas Resources of the Nation’s Outer 

Continental Shelf, 2016 (BOEM 2016a). 

Three different sets of flat price cases allow the decision maker to more clearly identify the extent to 

which net benefits vary under a wide range of general price levels, independent of other input 

assumptions such as the timing of activities. As recommended by the Office of Management and Budget, 

a real discount rate of 3 percent is used in the Proposed Program analysis to aggregate the 40 years of 

effects at a society-wide rate of time preference (OMB 2003). 

Table B-1: Price Cases 

Oil Natural Gas 

(per bbl) (per mcf) 

$40 $2.14 

$100 $5.34 

$160 $8.54 

Key: bbl = barrel of oil, mcf = thousand cubic feet of 

natural gas 

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The NSV calculation is conducted at three different price cases to show the wide range in available 

resources and impacts. The Secretary can relatively easily remove lease sales from the National OCS 

Program schedule if prices and industry interest fall. However, there are instances in which the Secretary 

cannot add lease sales to a National OCS Program schedule once it is in place, regardless of changing 

conditions, without following the same multi-step, time-consuming process. 

The relationship among price cases, economically recoverable resource estimates, and activity levels is 

not linear. This is clearly displayed in the DPP in Table 5-1 in Section 5.3.6, where resources are ranked 

by the $100/barrel oil price case. If the UERR were ranked by the $40/barrel or $160/barrel oil price 

cases, the ranking of planning areas would be different. 

1.3 NSV STEP 2: NET ECONOMIC VALUE 

After BOEM estimates the resources’ gross revenue, the second stage in the NSV analysis is to calculate 

the NEV. The NEV equals the discounted gross revenue from the produced oil and natural gas minus the 

discounted costs of exploring, developing, producing, and transporting the oil and natural gas to the 

market (i.e., the costs required to realize the economic value of the resources). The NEV can be 

considered as the present value of the expected economic rent collected from development of the UERR. 

The Federal Government, as lessor, collects most of the NEV as transfer payments in the form of cash 

bonuses, rentals, royalties, and taxes. The lessees, as private firms, retain the remainder as economic 

profits that could be distributed to shareholders or reinvested in exploration and development projects. 

The NEV therefore can be equated to the sum of the present values of government revenue and a measure 

of after-tax profits. 

The NEV for undiscovered resources in unleased portions of each planning area is calculated by assuming 

hypothetical schedules of activities covering exploration, development, production, and transportation of 

the UERR. BOEM’s NEV estimates for the planning areas analyzed use the same schedules of 

exploration, development, and production activities that are used in the environmental and social cost 

analysis. As discussed, the schedule of activities assumes that all resources are leased in the first year and 

explored, developed, and produced as quickly as possible, realizing the basic constraints of the particular 

region. The activities are expressed in aggregated terms, such as exploration wells drilled, platforms 

installed, and resources produced. Costs specified for the activities are consistent with the costs used for 

estimating the UERR. Costs are scaled for the different price cases using a cost-price “elasticity factor.”1 

Based on the calculated government share and general estimates of foreign shareholder proportions in 

foreign companies, we use only 95 percent of our estimate of NEV to measure the domestic portion of 

NEV from a planning area.2 In the DPP, Table 5-3 in Section 5.3.3 shows the domestic NEV estimates in 

the three columns under the Net Economic Value column header. 

1 Elasticity is a measure of responsiveness. In this case, the cost-price elasticity measures the responsiveness of OCS oil 

development costs to changes in oil prices. The cost-price elasticity was defined based on internal analyses that found that a 

statistically significant relationship exists between crude oil price and an index of upstream capital cost. These analyses were 

based in part on indices developed by IHS-CERA, Inc., and were applied to all cost components. 2 This reduction is described in BOEM 2017b. 

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1.4 NSV STEP 3: NET SOCIAL VALUE 

The final stage in the NSV analysis subtracts external costs from a planning area’s NEV. Beyond the 

private costs already captured in the NEV estimates, society incurs environmental and social costs from 

the activities and facilities associated with OCS oil and natural gas exploration, development, and 

production. The NSV equals the NEV less the present value of environmental and social costs anticipated 

from the oil and gas activities in each planning area. Environmental and social costs arise from air quality 

degradation, oil spills, visual and ecological disturbance, and pre-emption of other land uses during the 

exploration, development, production, and transportation of OCS oil and natural gas resources. In the 

DPP, Table 5-3 in Section 5.3 presents BOEM’s estimates for the NSV, including the environmental and 

social costs associated with the development of the UERR in OCS planning areas analyzed. 

BOEM uses the revised Offshore Environmental Cost Model (OECM) to estimate both the environmental 

and social costs that would result from OCS activities (Industrial Economics, Inc. and SC&A, Inc. 2015). 

The OECM models the impact of typical activities associated with OCS production and small oil spills 

occurring on the OCS. The model uses economic inputs, resource estimates, and exploration and 

development scenarios as the basis for its calculations. It is not designed to represent impacts from 

catastrophic discharge events3 or impacts on unique resources such as endangered or threatened species4 

because these impacts are subject to greater uncertainty and are not as easily monetized. 

The OECM calculates the environmental and social costs using the same OCS exploration and 

development activities used in the NEV analysis. Costs are computed for each of the following categories 

from activities associated with exploration, development, production, and transportation that might occur 

with new OCS production: 

• environmental costs (air quality and ecology) 

• social costs (recreation, property values, subsistence harvests, and commercial fishing). 

The OECM estimates air emissions for nine different pollutants: oxides of nitrogen (NOx), sulfur oxides 

(SOx), particulate matter with a diameter of 10 micrograms and 2.5 micrograms (PM10 and PM2.5, 

respectively), carbon monoxide (CO), volatile organic compounds (VOCs), carbon dioxide (CO2), 

methane (CH4), and nitrous oxide (N2O). 

3 The OECM only considers a range of oil spills up to 100,000 barrels. Given the unpredictable nature of catastrophic oil spills 

including the many factors that determine severity, efforts to quantify unexpected costs are less meaningful and more uncertain 

than the other measures considered in the NSV analysis. In addition to the difficulty in calculating the cost of the potential 

impacts of a catastrophic spill, there are similar difficulties in calculating the risk. For these reasons, the risk and impact of 

catastrophic oil spills are not considered in the NSV analysis. Catastrophic oil spills are discussed and considered in Chapter 7 

and in the paper Economic Inventory of Environmental and Social Resources Potentially Impacted by a Catastrophic Discharge 

Event within OCS Regions (Industrial Economics, Inc. 2014). 4 Impacts on unique resources such as endangered species will be discussed in more detail in the Programmatic EIS prepared in 

conjunction with the Proposed Program decision document. Further, these impacts could be subject to mitigation measures at 

later stages in the lease sale process. 

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The OECM applies a monetary value to the first five pollutants, which are known as “criteria air 

pollutants,” and also to VOCs, which is a precursor to the criteria air pollutant ozone, for which the 

U.S. Environmental Protection Agency (USEPA) regulates through the National Ambient Air Quality 

Standards. Greenhouse gas (GHG) emissions in the form of CO2, CH4, and NOx, are included in the 

discussion of non-monetized impacts. 

After reviewing the assumptions underlying the OECM, as well as the current best available information 

on the impacts on certain species, BOEM determined that, with regard to polar bears and their estimated 

replacement value, the range of potential impacts and level of uncertainty in the estimates were 

inconsistent with the uncertainty considered in the remaining environmental and social cost estimates. 

The heightened level of uncertainty with respect to polar bears causes anomalous model results and, thus, 

BOEM opted not to include the OECM polar bear results for the NSV analysis conducted at this stage. 

However, based on the available information on the impacts and valuation of polar bears, BOEM found 

that the inclusion of the OECM polar bear results were unlikely to affect the relative ranking of planning 

areas by NSV. BOEM will continue to revise the calculations and assumptions in the model regarding 

the treatment of polar bears, with the intent of integrating this information in the revised OECM results to 

be published with the Proposed Program. 

It is important to note that at the DPP phase, BOEM does not compare the NSV of a planning area with 

the NSV that would occur in the absence of leasing. The DPP only considers the environmental and 

social costs of extracting OCS resources, while the Proposed Program and PFP consider incremental 

environmental and social costs. Incremental environmental and social costs are the costs of producing the 

resources on the OCS, less the environmental and social costs of the most likely energy market substitutes 

for these resources. A decision not to hold a sale in any or all of the planning areas means no new leasing 

would take place in those areas for at least five years and domestic oil and natural gas supply would be 

reduced. This supply reduction would cause only a small change in hydrocarbon prices so there would be 

little change in the quantity of oil and natural gas demanded. 

In addition to a small amount of reduced consumption, to fulfill demand in the absence of OCS activity or 

with reduced OCS activity, there would be increases in energy imports, onshore production, and fuel 

switching (e.g., oil to natural gas, oil to coal). This is an important trade-off in the decision of whether or 

not to include an area in the Proposed Program and PFP decision. However, the DPP analysis focuses on 

the ranking of all planning areas assuming that all UERR are leased and produced, and, therefore, it is not 

fitting to calculate the energy market substitutions and associated environmental and social costs. The 

incremental environmental and social costs calculated for the program areas in the 2017–2022 Program 

show that in the absence of a new National OCS Program, the reduced consumption and the 

environmental and social costs of relying on substitute sources of energy are equal to or greater than these 

costs from producing area resources under the PFP.

5 

5 This is shown in Table 1-7 of the Economic Analysis Methodology (BOEM 2016). 

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To conduct the NSV analysis for the DPP decision document and the subsequent analyses for the 

Proposed Program and PFP, BOEM’s analysis considers up to the point at which the oil and gas resources 

mix with other hydrocarbons. Thus, the “downstream” environmental and social costs of processing and 

refining OCS oil and gas are excluded. This approach was upheld by the U.S. Court of Appeals for the 

District of Columbia Circuit in Center for Biological Diversity v. United States Department of the 

Interior, where the court ruled that “the text of OCSLA does not require Interior to consider the impact of 

consuming oil and gas extracted under an offshore Leasing Program” (U.S. Court of Appeals 2009, at 

484 [emphasis added]). The opinion further states the following: 

“as the statutory language and our precedent show, Interior’s obligations under OCSLA 

extend to assessing the relative impacts of production and extraction of oil and gas on the 

localized areas in and around where the drilling and extraction occurred. Interior need 

not consider the impacts of the consumption of oil and gas after it has been extracted 

from the OCS” (Id.., at 485; emphasis added). 

Though not required for the National OCS Program analysis, to better inform decisionmakers on the 

impacts of OCS oil and gas leasing, BOEM did consider the full lifecycle GHG emissions for the 

2017-2022 Program in its report entitled OCS Oil and Natural Gas: Potential Lifecycle Greenhouse Gas 

Emissions and Social Cost of Carbon (BOEM 2016c). The report found that U.S. GHG emissions would 

vary only slightly given leasing decisions under the 2017–2022 Program. In fact, the report found that 

emissions could possibly increase in the absence of new OCS leasing given the energy market substitutes 

that would replace OCS production (BOEM 2016c). The full report is available at 

https://www.boem.gov/OCS-Report-BOEM-2016-065/. 

1.5 NON-MONETIZED IMPACTS 

There are other types of environmental and social costs and benefits that are not included in the OECM or 

monetized in the NSV analysis. The NSV analysis captures the important costs and benefits associated 

with new OCS leasing that can be reliably quantified and estimated. However, there are other potential 

impacts that cannot be monetized, which are discussed below. 

1.5.1 Non-monetized Costs 

1.5.1.1 Greenhouse Gas Emissions 

The OECM estimates the monetary value of possible damages from emissions for six pollutants (NOx, 

SOx, PM10, PM2.5, CO, and VOCs) but does not estimate a monetary value of damages from emissions for 

GHGs (CH4, CO2, and N2O). Nevertheless, the model does calculate the quantity of GHG emissions that 

would be emitted. As with the criteria pollutants, GHGs are calculated based on the exploration and 

development assumptions used in the other aspects of the NSV analysis. 

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Table B-2 shows the estimated emissions associated with the exploration and development of OCS 

resources in tons of CO2 equivalent (CO2e) for those areas that have hydrocarbon resource potential 

and/or development potential above negligible. Emissions of CH4and N2O were converted to tons of 

CO2e using the USEPA’s Greenhouse Gas Equivalencies Calculator (EPA 2016) of 25 times for CH4 and 

298 times for N2O.6 

Table B-2: Greenhouse Gas Emissions 

Millions of Tons of CO2 Equivalent (CH4, CO2, N2O) 

Planning Area $160 

Oil Price Case 

$100 

Oil Price Case 

$40 

Oil Price Case 

Central Gulf 172.2 231.7 266.7 

Western Gulf 106.7 153.5 169.2 

Chukchi Sea 0.0 47.8 60.4 

Southern California 27.7 43.7 54.6 

Eastern Gulf 32.6 40.1 44.9 

Beaufort Sea 5.4 33.8 37.9 

Mid-Atlantic 17.8 29.2 38.5 

Central California 14.5 22.4 29.4 

North Atlantic 13.1 22.1 22.1 

Northern California 8.3 15.1 22.4 

Cook Inlet 6.9 8.5 8.4 

Washington-Oregon 2.4 5.0 6.8 

North Aleutian Basin 4.4 4.5 4.6 

Gulf of Alaska 0.0 2.7 4.4 

South Atlantic 1.8 2.7 3.6 

Key: CH4=methane, CO2=carbon dioxide, and N2O=nitrous oxide. 

An expanded methodology for estimating the full lifecycle GHG emissions (i.e., emissions from upstream 

activities as well as the downstream impacts of refining and consumption of OCS oil and gas resources) is 

included in OCS Oil and Natural Gas: Potential Lifecycle Greenhouse Gas Emissions and Social Cost of 

Carbon (Wolvovsky and Anderson 2017). This report includes the GHG emission estimates associated 

with the anticipated production under the 2017–2022 Program and was published alongside the 

2017-2022 PFP. 

1.5.1.2 Onshore Infrastructure 

Another category of environmental and social cost that is not monetized in the NSV analysis is the 

development of onshore infrastructure that directly supports OCS oil and gas activities. In general, the 

NSV analysis only considers the impacts associated with extracting resources and transporting them to 

shore. BOEM recognizes that additional environmental and social costs can occur as the result of onshore 

development and considers them qualitatively here. The majority of these costs are too uncertain to 

model quantitatively at this stage given uncertainty surrounding the type, quantity, and location of 

6 The CO2e conversion factors reflect differences in the Global Warming Potential (GWP) of individual GHGs. The GWP for a 

specific GHG is predominantly a function of the average time the gas remains in the atmosphere and how strongly it absorbs 

energy. CO2 is used as the benchmark for comparison. For example, in the case of CH4, which has a 100-year GWP factor of 25, 

CH4 emissions will cause 25 times as much warming as an equivalent mass of CO2 emissions over that same 100-year period. 

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infrastructure needs as well as the unknown potential mitigation measures that other permitting agencies 

could require to minimize or avoid the environmental impact of any onshore support activities. As noted 

in the Final Programmatic Environmental Impact Statement (EIS) for the 2017–2022 Program 

(BOEM 2016a), BOEM is not the permitting or regulatory agency for onshore development. Much 

onshore infrastructure could be used for existing oil and gas activity onshore or in state waters, other 

industrial activity near the coasts, or from the energy market substitutes associated with the absence of a 

sale in a planning area. 

The NSV analysis includes the air quality impacts from onshore pipeline construction associated with 

development in the Chukchi Sea Planning Area. These impacts are relatively foreseeable, because an 

onshore pipeline would be required to connect the Chukchi Sea to the Trans-Alaska Pipeline System, and 

these costs are relatively straightforward to monetize using the same quality modeling already captured in 

the OECM. However, the NSV analysis does not consider other environmental impacts of a potential 

pipeline. 

In general, construction or development of onshore infrastructure could cause changes in air quality, 

impacts from reductions in coastal marshland, the value of ecosystem services lost (e.g., flood protection), 

or impacts on water quality. Onshore infrastructure and the possible impacts are discussed in more detail 

in the Final Programmatic EIS for the 2017–2022 Program (BOEM 2016b) and will be evaluated fully 

during the development of this National OCS Program and in the subsequent analyses accompanying 

specific lease sales. The following is a list of the different types of onshore infrastructure, which are 

generally associated with offshore oil and gas operations: 

• Port Facilities: Major maritime staging areas for movement between onshore industries and 

infrastructure and offshore leases. 

• Platform Fabrication Yards: Facilities in which platforms are constructed and assembled for 

transportation to offshore areas. Facilities can also be used for maintenance and storage. 

• Shipyards and Shipbuilding Yards: Facilities in which ships, drilling platforms, and crew 

boats are constructed and maintained. 

• Support and Transport Facilities: Facilities and services that support offshore activities. This 

includes repair and maintenance yards, supply bases, crew services, and heliports. 

• Pipelines: Infrastructure that is used to transport oil and gas from offshore facilities to 

onshore processing sites and ultimately to end users. 

• Pipe Coating Plants and Yards: Sites that condition and coat pipelines used to transport oil 

and gas from offshore production locations. 

• Natural Gas Processing Facilities and Storage Facilities: Sites that process natural gas and 

separate its component parts for the market, or that store processed natural gas for use during 

peak periods. 

• Refineries: Industrial facilities that process crude oil into numerous end-use and intermediateuse products. 

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• Petrochemical Plants: Industrial facilities that intensively use oil and natural gas and their 

associated byproducts for fuel and feedstock purposes. 

• Waste Management Facilities: Sites that process drilling and production wastes associated 

with offshore oil and gas activities. 

Any anticipated onshore infrastructure growth is dependent on existing infrastructure in the planning 

areas and changes in future offshore drilling. The level of existing onshore infrastructure and amount of 

new infrastructure varies among the OCS planning areas. While the development of onshore 

infrastructure to support OCS oil and gas operations could cause environmental and social costs, there 

would also be developmental economic benefits associated with the construction and operation of the 

facilities, which are similarly not included in the NSV analysis. 

1.5.1.3 Passive Use Values 

In general, the NSV analysis includes cost estimates of many types of use values, but does not include 

some values that would be associated as passive use values (also referred to as non-use values). Evidence 

of passive use values can be found in the trade-offs people make to protect or enhance environmental 

resources that they do not use. 

Within the NSV analysis, certain passive use values are not estimated. The various types of passive use 

values are as follows: 

• Option value: An individual’s current value includes the desire to preserve the opportunity to 

use a resource in the future. 

• Bequest value: An individual’s value for having an environmental resource available for his 

or her children and grandchildren to experience. It is based on the desire to make a current 

sacrifice to raise the well-being of one’s descendants. Bequest value is not necessarily 

equivalent to the value of any information gained as a result of delaying leasing activities. 

• Existence value: An individual’s utility could be increased by the knowledge of the existence 

of an environmental resource, even though the individual has no current or potential direct 

use of the resource. 

• Altruistic value: An individual’s concern for another. 

A large body of literature discusses studies of these values. Estimating passive use values via stated 

preference surveys, such as the contingent valuation method, requires significant time and resources, and 

has been subject to scrutiny regarding the validity of results due to their hypothetical nature (i.e., survey 

respondents express values but are not required to actually pay) (Roach and Wade 2006). While best 

practices have improved the implementation of these methods over time through integration of validity 

and scope tests (Shaw and Wlodarz 2013), these methods remains resource-intensive processes. 

To the extent that some passive use values exist in the literature, their ability to be transferrable to the 

BOEM context is probably quite limited. The values were developed using stated preference techniques 

and the results from such analyses are often highly dependent on the resource and specific context (which 

would include resource conditions, possible improvements or degradation as a result of policy changes, 

and payment vehicles). If one were interested in evaluating the extent to which households or individuals 

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hold passive use values for OCS oil and gas resources, original empirical research would need to be 

conducted because a benefit transfer approach would not be appropriate given the importance of the 

specific context for stated preference studies. Total economic value studies (passive use values are part of 

total economic value) are time consuming and expensive to conduct. These types of studies are most 

appropriate to conduct in situations where the resources under consideration are unique, where a set of 

defined changes to the resource can be easily identified, and where the resource(s) are not typically 

bought and sold in markets. It is not clear this is the case for OCS resources. OCS oil and gas resources 

are not unique and they are readily bought and sold in markets. 

More discussion on the ecological components not included in the NSV analysis is in the report entitled 

Forecasting Environmental and Social Externalities Associated with Outer Continental Shelf (OCS) Oil 

and Gas Development - Volume 1: The 2015 Revised Offshore Environmental Cost Model (OECM) 

(BOEM 2015a). 

1.5.1.4 Additional Impacts from Non-Catastrophic Oil Spills 

The NSV analysis quantifies the costs of animal mortality and lost habitat from an oil spill through habitat 

equivalency analysis, where costs are estimated in terms of the anticipated expense to restore or recreate 

damaged habitat. The NSV analysis, however, does not quantify the values above the restoration cost at 

which society could value the damaged resource (i.e., the OECM does not monetize the impacts on 

unique resources). Additional information is provided in both Volume 1 and 2 of the OECM 

documentation (2015). 

Further, the model does not include ecological costs associated with the use of dispersants or the air 

quality costs associated with response vessel activity in the event of an oil spill. Those responding to an 

oil spill could apply chemical dispersants to affected waters to enhance natural dispersion of spilled oil by 

reducing surface tension at the oil/water interface, increasing the likelihood that wave motion will break 

the oil into small droplets that are more easily dissolved into water. The use of dispersants can often be 

controversial, because the dispersants could impact marine species and the environment, particularly in 

shallow waters (ITOPF 2011). 

The impacts of dispersants and response vessel activity are not currently incorporated in the OECM. 

Adding such impacts to the model would require more detailed data on the likelihood of response activity 

in a given spill and an estimate of the likely impacts associated with dispersant use. While estimates of 

potential use could possibly be derived based on historical experience, detailed data relating dispersant 

use to specific impacts are not readily available. 

1.5.1.5 Additional Ecological Impacts 

The NSV analysis includes monetized impacts on ecological resources through oil spills, but does not 

monetize the impacts on these resources from general operations. For example, it does not capture costs 

to habitats or organisms from waste cuttings and drilling muds deposited on the ocean floor near OCS 

structures, auditory impacts and vessel strikes on marine mammals, or water quality impacts associated 

with produced water discharged from wells or non-oil discharges from platforms and vessels. BOEM 

continues to monitor research on these topics for incorporation in future analyses. 

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1.5.2 Non-monetized Benefits 

The OECM does not monetize certain benefits from OCS oil and gas activities because a credible 

assessment of monetized impacts cannot be made, owing to a lack of available data and inability to 

associate any monetized impacts specifically with new OCS leasing and production. Several categories 

of these non-monetized benefits, including recreational fishing and diving, national energy security, and 

the U.S. trade deficit, can only be evaluated qualitatively and are discussed below. 

1.5.2.1 Recreational Fishing and Diving 

Obsolete OCS oil and gas platforms can be converted to artificial reefs to support marine habitat. In the 

GOM, where the seafloor consists mostly of soft mud and silt, artificial reefs and platforms can provide 

additional hard-substrate areas for a variety of species. The benefits of artificial reefs are well 

documented and could increase the density of fish species around platforms as compared to natural reef 

sites (BOEM 2012b). 

Gulf coast states have recognized the potential importance of such aquatic structures to marine species 

and local activities. The artificial reef programs in these states, as part of the Rigs-to-Reefs program, 

have worked to facilitate the permitting, navigational requirements, and liability transfer for 

decommissioned and reefed rigs in Federal and state OCS waters. The reduction in pressure on natural 

surrounding reefs and the impact on local industries, and to a certain extent, the greater economy, 

illustrate the potential environmental and social benefits artificial reefs could provide. More information 

on the artificial reefs and the state programs are included in Appendix A-4 of the Gulf of Mexico OCS Oil 

and Gas Lease Sales: 2012–2017 Final Environmental Impact Statement (BOEM 2012b). The leasing 

from this National OCS Program is expected to increase the number of platforms in the GOM, providing 

increased gathering areas for commercial and recreational fishermen, and steering reefing activities 

towards artificial reef locations that tend to decrease navigational and commercial fishing burdens while 

increasing the attractiveness of sites for recreational and commercial use. 

While these benefits exist in the GOM planning areas, the impact on, or other similar benefits to, other 

planning areas are yet to be determined. 

1.5.2.2 National Energy Security 

Over the past 50 years, U.S. oil and gas demand, supply, and prices have increasingly shaped 

U.S. national energy policy concerns and national security issues. Because crude oil is used as a source 

of energy for many goods, services, and economic activities throughout the U.S. economy, supply 

disruptions and increases in energy prices affect nearly all U.S. consumers. 

Concerns over energy security stem from the importance of crude oil and natural gas within U.S. 

economic markets and the energy supply disruptions that can occur due to the characteristics and behavior 

of the global crude oil supply market. The externalities associated with oil supply disruptions—economic 

losses in GDP and economic activity—have been shown to be greater for imported oil than domestically 

produced oil. Increased domestic oil production can boost the share of stable supplies in the world market 

while increased oil imports, often from unstable regions, can have the opposite effect (Brown and 

Huntington 2010). Increased oil and gas production from the OCS can help mitigate the impact of supply 

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disruptions and spikes in oil prices on the U.S. economy, mitigating economic downturns as well as the 

amount of U.S. dollars sent overseas from purchases of crude oil imports. 

1.5.2.3 U.S. Trade Deficit 

Chapter 1 of the 2019–2024 DPP provides a discussion of energy’s importance in the balance of 

payments and trade, with an emphasis on the relationship to OCS production and imported oil. In 

particular, large expenditures on crude oil imports can stifle economic activity and slow down domestic 

economic growth, as well as impact the rate of U.S. inflation and reduce the real discretionary incomes of 

U.S. consumers (CRS 2010). Domestic production of oil from the OCS reduces the amount of oil that 

must be imported from abroad, thereby mitigating the effect that high domestic energy expenditures could 

have on the U.S. trade deficit. 

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Chapter 2 Fair Market Value Analysis: WEB3 Methodology 

As described in Section 10.1.2, at the National OCS Program stage, BOEM considers how the timing of 

offering planning areas for oil and gas leasing affects their value through the use of a hurdle price 

analysis. The hurdle price is the price below which delaying exploration for the largest potential 

undiscovered resource field in the sale area is more valuable than immediate exploration.7 BOEM uses 

the WEB3 (When Exploration Begins, Version 3) model to calculate the hurdle prices associated with 

each planning area. This appendix provides additional information on the methodology behind the hurdle 

price calculation. 

BOEM’s calculation of the hurdle price for the DPP is similar to that used in the 2017–2022 PFP. This 

approach is different from what was used in the 2017-2022 DPP analysis and incorporates the 

environmental and social costs of OCS activities in optimal timing of leasing decisions based on NSV. 

NSV is the NEV less the environmental and social costs. This will be described in more detail in this 

chapter. 

2.1 WEB3 CALCULATIONS 

BOEM uses the WEB3 model to calculate the social value of offering leases now versus waiting. 

WEB3 computes the social value of immediate leasing versus delays of 1 through 10 years. BOEM 

considers leasing in this 2019–2024 Program to be immediate leasing (2019), a one-year delay (2020) and 

up to a four-year delay (2023). Delays of 5 to 10 years are considered as leasing in 2024 through 2029, 

which are after the end of the 2019–2024 Program. If the social value of delaying leasing until the next 

National OCS Program (2024–2029) is higher than leasing at any time during this current period, then 

delaying the area until the next program could be optimal. This analysis is conducted for planning areas 

that have hydrocarbon resource potential and/or development potential above negligible. 

WEB3 calculates the NEV as: 

NNNNNN = QQ(PP − NN) − FF

In this equation, QQ is the quantity of resources, PP is price, NN is variable costs, and FFis fixed costs. Both 

the quantity of resources and price inputs are random variables determined by the WEB3 model. BOEM 

then adjusts the NEV for the environmental and social costs associated with development to calculate the 

NSV. 

7 All else being equal, the largest field tends to have the highest net value per equivalent barrel of resources, making it the least 

likely field to benefit from a delay in being offered for lease. BOEM used the 95th percentile field size as the approximate 

largest field size available in each planning area. 

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NNNNNN = NNNNNN − NNNNEE

In this equation, ESC is the estimate of environmental and social costs. BOEM then compares the 

expected value (denoted by the symbol NNtt+1) of the NSV if an area is available for lease immediately 

with the expected value of the NSV if leasing is delayed. WEB3 calculates the expected social value in 

the next period (in time, tt + 1) based on the choice to lease or wait in the first period (e.g., “What is the 

value tomorrow of my choice to explore today?”). The social value of leasing is calculated as: 

NNNNLL = NNtt+1[NNNNNN(rrss)|llllllllll iiii tt] 

The social value of waiting is calculated as: 

NNNNWW = NNtt+1[NNNNNN(rrss)|wwlliitt iiii tt] 

In this equation, NNNNLL is the social value of leasing and NNNNWWis the social value of waiting. The calculation 

of social value under both the leasing and waiting scenarios are discounted at the social discount rate, rrss. 

This analysis uses a social discount rate of 3 percent. 

To calculate the hurdle price, the WEB3 is run iteratively for various (higher) start prices until the first 

start price is found, at which leasing in 2019–2024 produces a higher NSV than leasing in 2024 or after. 

This price then becomes the hurdle price, the price below which waiting to lease is optimal when 

compared to leasing immediately. 

2.2 HURDLE PRICE ASSUMPTIONS 

To calculate the hurdle price, BOEM employs various assumptions to estimate the value of the resources 

and how this value might change with delay. This section outlines the assumptions for resources, prices, 

private costs, and social costs. 

2.2.1 Resource Assumptions 

The first step in calculating hurdle prices is to identify the resource assumptions in each planning area. 

WEB3 uses two separate resource assumptions in calculating the potential field size in a region: the 

probability that the lessee finds resources during exploration, and, if resources are found, the expected 

field sizes. BOEM assumes a 20 percent success rate for exploratory drilling. BOEM uses an 

approximation of the largest field size in each planning area as the expected field size. The largest field 

size, all else being equal, tends to have the highest net value per equivalent barrel of resources and thus 

would be the most profitable in a sale and provide the lowest hurdle price. The reason for focusing on 

just the largest field is that the decision criterion using the hurdle price is intended to be conservative, to 

avoid the risk of withholding, on economic grounds, an area that might have at least one field that ought 

to be developed immediately. This decision is appropriate at the programmatic level where the decision 

is simply made whether or not to include an area in the National OCS Program, not to make a final 

decision on holding the sale, its configuration, and its financial terms. 

For the purposes of determining hurdle prices, BOEM analyzed the distribution of expected undiscovered 

field sizes associated with each planning area based on results from BOEM’s Assessment of Undiscovered 

Technically Recoverable Oil and Gas Resources of the Nation’s Outer Continental Shelf, 2016 

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(BOEM 2016; herein referred to as the 2016 National Assessment) estimates at the mean probability. In 

general, the 2016 National Assessment addresses undiscovered resources in a framework of field size and 

probability. The field size framework is provided by the United States Geological Survey (USGS) field 

size classes, which enables grouping fields. For example, there might be two fields in a range of 

2 to 4 million BOE (MMBOE); three fields in the next class covering 4–6 MMBOE; and so on. The 

corresponding large field size from which hurdle prices are calculated were then associated with the 95th 

percentile of the field size distribution. The 95th percentile field size provides a practical estimate of a 

large field size by eliminating the tails of the resource distribution. Although the 95th percentile 

corresponds to a 1 in 5 chance of discovering a field that exceeds the largest field size shown, this 

percentile constitutes a reasonable assumption based on known discoveries and/or analog information in 

each planning area. BOEM reviewed discovered field sizes and determined that the 95th percentile field 

provides an appropriate estimation of a large field size for the hurdle price analysis. 

2.2.2 Price Assumptions 

The WEB3 model incorporates a specific type of price model that is appropriate for the analysis of real 

options for commodities like oil and gas. The price model in WEB3 represents the range of possible 

future prices generated by a specific algorithm that models a mean-reverting stochastic process. In this 

formulation, the change in price from one time to the next is random, and the probability of a step up or 

down reflects a tendency for movement toward the mean level. WEB3 calculates price as the following: 

= PPtt[

TTtt+1 PPtt+1 ]

ααεεtt+1 PPtt

Where: PPtt is the real price in time t; TTtt+1 is the real mean trend price in time t; αα is the reversion rate; and 

εεtt+1 is a random term. The three inputs to this price model are the trend price, the reversion rate, and the 

volatility that is incorporated in the random term. The mean trend gives the price level in each year that 

market prices tend to revert to after they have randomly moved off of trend. In other words, if the actual 

price in 2019 happens to be in the vicinity of $50/boe and the trend price is specified as a flat $90, then 

the model represents the 2020 price by combining an upward tendency—since the 2019 price is below the 

mean trend—and a random factor that might be upwards or downwards. The real price in time t = year of 

lease sale is the “start price” of this process. In the application to the issue of the timing of lease sales, 

theWEB3 model is solved for the lowest “start price” price that provides a greater net social value from 

leasing in the current National OCS Program versus waiting until the future. That solution is what is 

called the hurdle price. If the market price at the time of leasing happens to be lower than the calculated 

hurdle price, then a delay of leasing is indicated. 

For the hurdle price analysis, BOEM assumed that the trend price was the BOE price combining $90 per 

barrel (bbl) of oil and $4.80 per thousand cubic feet (mcf) of natural gas in 2019 dollars. Following the 

mean-reversion framework, we assumed that the starting price (which is equivalent to the hurdle price) 

will revert to the trend price at a rate of 12 percent of the difference per year. The volatility (that is, the 

annualized standard deviation) is assumed to be 32 percent. These parameters were estimated by BOEM 

by a regression analysis of historical oil and gas prices, where the regression model was the meanreverting model. 

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An important aspect of WEB3 is that resource estimates and prices are input as BOE values. The gas-oil 

ratios in each planning area varies significantly, so market and mean trend prices per BOE in each area 

reflect that area’s weighting of the gas and oil price based on the area-specific gas-oil ratio. See 

Chapter 10 in the DPP for hurdle price results for more detail. 

2.2.3 Private Cost Assumptions 

Once the largest field size is set (approximated by the 95th percentile field size), the WEB3 model 

requires estimates of the private exploration and development costs associated with that field. 

Development and production cost inputs for the WEB3 model are consistent with those used in the 

calculation of the NEV in Section 5.3. The costs used for both analyses are based on the commercial 

Que$tor cost modeling system, data collected by BOEM for the socioeconomic analysis of the National 

OCS Program (i.e., the economic impact model MAG-Plan), and cost estimates used in tract evaluations. 

BOEM identified an approximate level of infrastructure required for the size of the largest field in each 

planning area and calculated total costs based on the individual components. A lessee’s decision to 

develop is determined in WEB3 by the net present value of the project. In calculating the net present 

value of a project for its developer, a real discount rate of 7 percent is used. Note that this is different 

from the social discount rate, 3 percent, that is used to calculate the net social value of revenues and social 

costs. 

2.2.4 Environmental and Social Cost Assumptions 

BOEM estimates the environmental and social costs of the exploration, development, production, 

transport, and decommissioning of the largest field size in each planning area using the OECM. The 

environmental and social costs include air emissions, oil spill risks, etc. These costs are subtracted 

because they are anticipated to be incurred from the traditional annual input measures of the NEV 

(e.g., gross revenues and private costs). By including environmental and social costs into the hurdle price 

analysis, the hurdle prices increase slightly over what they would be solely focusing on NEV. The 

increase is due to the fact that the inclusion of environmental and social costs changes the NEV into a 

lower NSV, thereby providing a larger proportional effect of higher prices on the underlying value of a 

given field size. The amount that the hurdle price changes owing to the inclusion of environmental and 

social costs in each planning area varies depending on the relative magnitude of these costs and the 

estimate of NEV in each area. 

Of course, the hurdle price calculation does not include every facet of uncertainty and is not intended to 

accurately predict future price paths. However, the hurdle price analysis still provides a useful screening 

tool to consider areas for inclusion in the 2019–2024 Program. 

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Chapter 3 References 

BOEM (Bureau of Ocean Energy Management). 2016a. Assessment of Undiscovered Oil and Gas Resources of the 

Nation’s Outer Continental Shelf, 2016. Available online at https://www.boem.gov/2016-NationalAssessment-Fact-Sheet/. Accessed August 1, 2017. 

BOEM. 2016b. Economic Analysis Methodology for the Five-Year OCS Oil and Gas Leasing Program for 

2017-2022. June 2016. BOEM 2017-022. Available online at http://www.boem.gov/uploadedFiles/ 

BOEM/Oil_and_Gas_Energy_Program/Leasing/Five_Year_Program/2012-

2017_Five_Year_Program/PFP%20EconMethodology.pdf. Accessed June 30, 2017. 

BOEM. 2016c. OCS Oil and Natural Gas: Potential Lifecycle Greenhouse Gas Emissions and Social Cost of 

Carbon. November. Available online at https://www.boem.gov/OCS-Report-BOEM-2016-065/. Accessed 

August 8, 2017. 

Brown, S.P.A and H.G. Huntington. 2010. Reassessing the Oil Security Premium. Resources for the Future 

Discussion Paper 10-05. 

Industrial Economics, Inc. 2014b. Economic inventory of environmental and social resources potentially impacted 

by a catastrophic discharge event within OCS regions. U.S. Department of the Interior, OCS Study BOEM 

2014-669. 

Industrial Economics, Inc. and SC&A, Inc. 2015. Forecasting Environmental and Social Externalities Associated 

with Outer Continental Shelf (OCS) Oil and Gas Development – Volume 1: The 2015 Revised Offshore 

Environmental Cost Model (OECM). U.S. Department of the Interior, Bureau of Ocean Energy 

Management. Available online at https://www.boem.gov/ESPIS/5/5492.pdf. Accessed August 2, 2017. 

OMB (U.S. Office of Management and Budget). 2003. Circular A-4: Regulatory Analysis. September. Available 

online at http://www.whitehouse.gov/omb/circulars_a004_a-4. Accessed June 30, 2017. 

Wolvovsky, E. and Anderson, W. 2016. OCS Oil and Natural Gas: Potential Lifecycle Greenhouse Gas Emissions 

and Social Cost of Carbon. BOEM OCS Report 2016-065. 44 pp. 

USEPA (U.S. Environmental Protection Agency). May 2016. Greenhouse Gas Equivalencies Calculator. 

Available online at https://www.epa.gov/energy/greenhouse-gases-equivalencies-calculator-calculationsand-references. Accessed June 30, 2017. 

References B-21 January 2018