CC SR 20180807 L - Offshore Drilling Status UpdateRANCHO PALOS VERDES CITY COUNCIL MEETING DATE: 08/07/2018
AGENDA REPORT AGENDA HEADING: Consent Calendar
AGENDA DESCRIPTION:
Consideration and possible action to receive an update on the status of Federal
proposals for off-shore drilling
RECOMMENDED COUNCIL ACTION:
(1) Receive and file.
FISCAL IMPACT: None
Amount Budgeted: N/A
Additional Appropriation: N/A
Account Number(s): N/A
ORIGINATED BY: Kit Fox, AICP, Senior Administrative Analyst
REVIEWED BY: Gabriella Yap, Deputy City Manager
APPROVED BY: Doug Willmore, City Manager
ATTACHED SUPPORTING DOCUMENTS:
A. Pacific Coast Planning Areas (page A-1)
B. Existing Pacific Coast Lease Areas (page B-1)
C. SLC letter opposing the 2019-2024 National Leasing Program (page C-1)
D. Senate Resolution No. 73 opposing the 2019-2024 National Leasing
Program (page D-1)
E. Coastal Commission comments on the 2019-2024 National Leasing
Program (page E-1)
BACKGROUND AND DISCUSSION:
On January 4, 2018, the Bureau of Ocean Energy Management (BOEM) announced the
release of its draft proposed program to initiate new lease sales for off-shore oil and gas
drilling. The draft program proposes to two (2) new lease sales within the Southern
California Planning Area, which extends from San Luis Obispo County south to the
Mexican border (Attachment A). Currently, there are forty-three (43) producing leases
in the Southern California Planning Area, but there have been no new leases in this
area since 1984 (Attachment B).
The draft proposed program is available for review on-line at https://www.boem.gov/NP-
Draft-Proposed-Program-2019-2024. A series of public meetings to solicit input on the
program were held around the country earlier this year. In California, a public meeting
1
was held in Sacramento on February 8, 2018. Staff has recently reviewed the BOEM
webpage for this project and found that there is no new or additional information
available about its status.
In response to the request from BOEM for public input on the project, the State Lands
Commission (SLC) issued a press release and formal comments opposing any new
drilling leases on February 7, 2018 (Attachment C). Since the Commission has the
authority to issue leases within State waters (i.e., the 3-mile limit), it is the Commission’s
position that any oil, gas or other mineral resources extracted from new leases within
Federal waters cannot be brought ashore within California. Opposition to this program
has also been expressed with the adoption of State Senate Resolution No. 73 on
February 6, 2018 (Attachment D) and in letters and comments from the California
Coastal Commission (Attachment E).
In addition to SLC’s opposition to the 2019-2024 National Leasing Program, it should
also be noted that the SLC and the California Coastal Commission have also been
working to cap and decommission several existing offshore and onshore oil and gas
facilities within the Southern California Planning Area, including:
• The Becker well in Summerland (March 2018)
• Platform Holly offshore from Goleta (February 2018)
• Rincon Island offshore from Mussel Shoals (December 2017)
At this time, the potential locations of the two (2) new proposed lease sales in the
Southern California Planning Area have not been identified, but the new leases are
expected to commence in 2020 and 2022. Staff will continue to monitor this issue and
provide periodic updates to the City Council, primarily through the Weekly
Administrative Report.
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This map has been carefully prepared from the best existing data sources available at the time of its completion, but the Bureau of Ocean Energy Management and the Bureau of Safety and Environmental Enforcement donot guarantee the accuracy and are not responsible or liable for reliance thereon. It is not a legal document for federal leasing purposes nor is it to be used for navigation. The OCS Official Protraction Diagram and Leasing Mapsshould be consulted for area measurements and location of individual blocks.
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Channel Islands National Park
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Pacific Outer Continental Shelf Region
Bureau of Ocean Energy ManagementBureau of Saftey and Environmental Enforcement
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senate, california legislature—2017–18 regular session
Senate Resolution No. 73
Introduced by Senators McGuire, Allen, Atkins, Beall, De León,
Dodd, Hertzberg, Hill, Jackson, Monning, Skinner, and Wiener
Relative to a new 5-year National Offshore Oil and Gas Leasing
Program on the Outer Continental Shelf
WHEREAS, California’s iconic coastal and marine waters are one
of our state’s most precious resources, and it is our duty to protect our
coast and ensure the long-term viability of California’s wildlife and
fisheries resources, as well as the multibillion dollar commercial and
recreational fishing and tourism industries; and
WHEREAS, Hundreds of millions of California residents and visitors
enjoy the state’s ocean and coast for recreation, exploration, and
relaxation; and tourism and recreation comprise the largest sector of
the state’s $44.5 billion ocean economy; and
WHEREAS, 500,000 jobs rely on a clean California coast, including
California’s $7 billion commercial fishing industry; and
WHEREAS, There have been no new offshore oil and gas leases in
California since the 1969 blowout of a well in federal waters; and
WHEREAS, Beginning in 1921, and many times since, the California
Legislature has enacted laws that withdrew certain offshore areas from
oil and gas leasing, and by 1989 the state’s offshore oil and gas leasing
moratorium was in place; and
WHEREAS, In 1994, the California Legislature made findings in
Assembly Bill 2444 (Chapter 970 of the Statutes of 1994) that offshore
oil and gas production in certain areas of the state’s waters poses an
unacceptably high risk of damage and disruption to the marine
environment; and
WHEREAS, In the same bill, the Legislature created the California
Coastal Sanctuary Act, which included all of the state’s unleased waters
subject to tidal influence and prohibited new oil and gas leases in the
sanctuary, unless the President of the United States has found a severe
energy supply interruption and has ordered distribution of the Strategic
Petroleum Reserve, the Governor finds that the energy resources of the
sanctuary will contribute significantly to alleviating that interruption,
97
D-1
and the Legislature subsequently amends Chapter 970 of the Statutes
of 1994 to allow that extraction; and
WHEREAS, Section 18 of the federal Outer Continental Shelf Lands
Act (43 U.S.C. Sec. 1331 et seq.) requires the preparation of a
nationwide offshore oil and gas leasing program that sets a five-year
schedule of lease sales implemented by the Bureau of Ocean Energy
Management within the United States Department of the Interior; and
WHEREAS, Consistent with the principles of Section 18 and the
resulting regionally tailored leasing strategy, the current exclusion of
the Pacific Outer Continental Shelf from new oil and gas development
is consistent with the longstanding interests of the Pacific coast states,
as framed in the 2006 West Coast Governors’ Agreement on Ocean
Health adopted by the Governors of California, Washington, and
Oregon; and
WHEREAS, In November 2016, the federal Bureau of Ocean Energy
Management released a final 2017–22 leasing program that continues
the moratorium on oil and gas leasing in the undeveloped areas of the
Pacific Outer Continental Shelf; and
WHEREAS, Governor Brown, in December 2016, requested that
then President Obama permanently withdraw California’s Outer
Continental Shelf from new oil and gas leasing, and along with previous
California Governors, has united with the Governors of Oregon and
Washington in an effort to commit to developing robust renewable
energy sources to reduce our dependence on fossil fuel and help us
reach our carbon emission goals; and
WHEREAS, The California Legislature has led the nation with its
landmark climate change legislation, requiring ambitious greenhouse
gas emission reductions of a 40-percent emissions reduction below
1990 levels by 2030, and achieving a renewables portfolio standard of
50 percent by 2030. California must lead the nation in fostering the
transition away from offshore fossil fuel production to protect both our
climate and oceans from the damaging impacts of climate change, which
will affect all life on earth for generations to come; and
WHEREAS, A Field/IGS (Institute of Governmental Studies) poll
in 2016 found 90 percent of Californians believe that protecting the
coastline is important and a Public Policy Institute of California 2017
survey found support for drilling here at an all-time low of 25 percent;
and
WHEREAS, President Donald Trump’s proposed five-year National
Offshore Oil and Gas Leasing Program represents a renewed call for
97
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D-2
opening offshore areas for drilling and for lifting moratoriums on energy
production in federal areas, that could lead to more oil spills, increased
dependence on fossil fuel, and more damaging impact from climate
change; and
WHEREAS, The California Legislature considers new oil and gas
development offshore of the Pacific coast to be a threat to the nation’s
economy and national security, and to the state’s ambitious renewable
energy goals; and
WHEREAS, The California State Senate has previously adopted
Senate Resolutions 35, 44, and 51 in 2017, which support the current
federal prohibition on new oil or gas drilling in federal waters offshore
California, oppose attempts to modify the prohibition, and defend the
National Marine Sanctuaries of the United States; and
WHEREAS, Secretary of the Interior Ryan Zinke announced plans
on January 4, 2018, for a Draft Proposed Program that would include
nearly the entire U.S. Outer Continental Shelf for potential oil and gas
lease sales pursuant to President Trump’s executive order on American
energy that was issued on April 28, 2017; and
WHEREAS, The proposed program would open up 6 leases off the
coast of California, which would be the first sale in the Pacific Region
since 1984; and
WHEREAS, Despite the Trump administration’s assertion of support
for the program from state and local governments, the States of
Washington, Oregon, and California have been consistently united in
their opposition to any new oil and gas activities off their coasts, which
has resulted in the exclusion of the Pacific coast’s Outer Continental
Shelf from any National Outer Continental Shelf Program since the
1989–92 program; and
WHEREAS, Republican and Democratic Governors alike are opposed
to the expansion of lease sales off the coast of the United States; and
WHEREAS, The Trump administration announced on January 9,
2018, that it retracted its plan to expand offshore oil leases off the coast
of Florida after receiving feedback from Florida Republican Governor
Rick Scott, and the Senate believes California should receive this same
exemption; and
WHEREAS, The Trump administration has taken the position that
state and local input is an important part of the leasing process; now,
therefore, be it
Resolved by the Senate of the State of California, That the Senate
strongly urges the President and the Congress of the United States to
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permanently safeguard and protect the Pacific coast’s Outer Continental
Shelf from new oil and gas leasing, and declares the Senate’s
unequivocal support for the current federal prohibition on new oil or
gas drilling in federal waters offshore of the Pacific coast, its opposition
to the proposed 5-year National Offshore Oil and Gas Leasing Program
on the Outer Continental Shelf or any attempts to modify that
prohibition, and its determination to consider any appropriate actions
to maintain the current prohibition; and be it further
Resolved, That the Secretary of the Senate transmit a copy of this
resolution to the National Program Manager of the federal Bureau of
Ocean Energy Management as the public comment of the Legislature
in opposition to the proposed new 5-year National Offshore Oil and
Gas Leasing Program on the Outer Continental Shelf; and be it further
Resolved, That the Secretary of the Senate transmit copies of this
resolution to the President and the Vice President of the United States,
to the Governor of California, to the Majority and Minority Leaders of
the United States Senate, to the Speaker and the Minority Leader of the
United States House of Representatives, to each Senator and
Representative from California in the Congress of the United States, to
the Secretary of the United States Department of the Interior, to the
Director of the federal Bureau of Ocean Energy Management, and to
each member of the California State Senate and Assembly.
Senate Resolution No. 73 read and adopted by the Senate February 5,
2018.
Attest:
Secretary of the Senate
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STATE OF CALIFORNIA—CALIFORNIA NATURAL RESOURCES AGENCY EDMUND G BROWN, G OVERNOR
CALIFORNIA COASTAL COMMISSION
45 FREMONT, SUITE 2000
SAN FRANCISCO, CA 94105-2219
VOICE AND TDD (415) 904-5200
FAX (415) 904-5400
February 7, 2018
Kelly Hammerle
National Oil and Gas Leasing Program Development and Coordination Branch
Office of Strategic Resources - Leasing Division
Bureau of Ocean Energy Management (BOEM) (VAM-LD)
Sterling, VA 20166
RE: Comments on the 2019-2024 Draft Proposed National Oil and Gas Leasing Program
(Docket ID: BOEM-2017-0074)
Dear Ms. Hammerle:
In 1969, three million gallons of crude oil spilled off the coast of Santa Barbara, a tragedy that
tarred miles of coastline, suffocated wildlife, galvanized the modern environmental movement
and contributed to the creation of our agency. Since that time, the Coastal Commission has been
dedicated to protecting and preserving the magnificent California coast. We were outraged to
learn that BOEM had recklessly threatened the health of California’s coastal environment and
the future of its multi-trillion dollar economy by proposing to expand drilling off the coast.
California depends on the international draw of its iconic beaches and ocean waters and it is the
Coastal Commission’s mandate to protect this fragile and precious natural resource.
Virtually all of California’s coastal economy and valuable coastal resources would be at
significant risk under this program. These dangers have not diminished since the devastating
1969 oil spill. Subsequent massive spills around the nation, such as the Exxon Valdez and
Deepwater Horizon oil spills, and less massive but still significantly resource damaging 2015
Plains oil spill in Santa Barbara, are continued reminders of the inherent risks associated with
offshore oil development.
While the Department of Interior appears to be sending mixed signals about whether (or at what
point) Florida will be removed from the Program, due to its “unique” coastal tourism economy,
California merits the same consideration as Secretary Zinke announced for Florida – removal
from the Program. California’s economy is roughly three times that of Florida, with over $2
trillion of its $2.35 trillion dollar gross domestic product derived from coastal counties,
according to the National Ocean Economics Program. If offshore drilling poses a risk to
Florida’s economy, the risk to California’s is three times greater.
E-1
STATE OF CALIFORNIA—NATURAL RESOURCES AGENCY EDMUND G BROWN, G OVERNOR
CALIFORNIA COASTAL COMMISSION
45 FREMONT, SUITE 2000
SAN FRANCISCO, CA 94105-2219
VOICE AND TDD (415) 904-5200
FAX (415) 904-5400
March 7, 2018
Ms. Kelly Hammerle
National Oil and Gas Leasing Program Development and Coordination Branch
Leasing Division
Office of Strategic Resources
Bureau of Ocean Energy Management (BOEM) (VAM-LD)
45600 Woodland Road
Sterling, Virginia 20166-9216
RE: Comments on the 2019-2024 Draft Proposed National Oil and Gas Leasing Program
(Docket ID: BOEM-2017-0074)
Dear Ms. Hammerle:
The Chair of the California Coastal Commission (“Commission”), Dayna Bochco, has submitted
a comment letter dated February 7, 2018, to this docket, urging BOEM to remove California
from the 2019-2024 Draft Proposed National Oil and Gas Leasing Program (“Draft Proposed
Program”). The purpose of this letter is to elaborate on why California is not a suitable location
for any additional offshore oil and gas development.
The Commission has long opposed efforts to expand oil and gas leasing, exploration and
production off the California coast. We have maintained since the early 1980s that new offshore
leasing would conflict with the California Coastal Management Program (“CCMP”) and
compromise California’s productive coastal ecosystems and vital coastal economy. Today, with
the clear evidence and alarming effects of climate change all around us, we are more committed
than ever to these principles. Californians across the political spectrum have recognized this
danger and joined together to address it by, among other things, enacting strong coastal
protection laws and more recently, adopting ambitious mandates for renewable energy use and
greenhouse gas reductions. Adding California to the national leasing program would be a step
backwards in our efforts to protect our coast and our natural environment and combat climate
change. As Chair Bochco stated in her letter, the Coastal Commission is steadfast in its
commitment to protect our fragile and precious coastal resources.
The purpose of this supplemental letter is to demonstrate that her concerns are not only
supported by sound science and Coastal Act considerations, but by BOEM’s own regulatory
framework. As BOEM is aware, the Commission implements California’s federally approved
coastal management program and serves as the only California agency with federal Coastal Zone
Management Act authority over oil and gas leasing, exploration, development and production
activities on the Outer Continental Shelf (OCS). Consequently, the Commission will conduct a
federal consistency review to determine the consistency of any proposed lease sales, exploration,
and production plans, and associated activities in federal waters with the enforceable policies of
the California Coastal Act. However, even looking solely at the guiding principles set forth in
E-2
CCC Staff Comments to BOEM on 2019-2024 OCS Leasing Plan
March 7, 2018
Page 2
2
the OCS Lands Act that provide the foundation for BOEM’s analysis of future leasing, it
becomes clear that California is not an appropriate location for additional offshore oil and gas
leasing and development.
The OCS Lands Act requires that the Secretary of the Interior consider eight factors when
determining the size, timing, and location of oil and gas activities among the different OCS areas
to be included in the five-year leasing program. These factors include: (A) Geographical,
Geological and Ecological Characteristics, (B) Equitable Sharing of Developmental Benefits and
Environmental Risks, (C) Location with Respect to Regional and National Energy Markets and
Needs, (D) Location with Respect to Other Uses of the Sea and Seabed, (E) Laws, Goals and
Policies of Affected States Identified by Governors, (F) Interest of Potential Oil and Gas
Producers, (G) Relative Environmental Sensitivity and Marine Productivity, and (H)
Environmental and Predictive Information. Although we will not be addressing Factor F
(Interest of Potential Oil and Gas Producers) in this letter, application of each of the remaining
factors to the California OCS supports our Chair’s conclusion that California is not suitable for
further offshore oil and gas leasing development.
Geographical, Geological, and Ecological Characteristics
Section 18(a) of the OCS Lands Act requires BOEM to include information about a Planning
Area’s geographical, geological and ecological characteristics in its analysis of the net social
value of the Area’s oil and gas resources. However, as discussed below, several crucial elements
were not adequately analyzed in BOEM’s initial evaluation of the Pacific Region, including the
three California Planning Areas.
First, BOEM’s assessment did not properly consider and appropriately weigh the uncertainty in
the estimates of available oil and gas resources. BOEM’s Draft Proposed Program includes an
estimate and ranking by Planning Area of undiscovered economically recoverable resources
(“UERR”). As noted in the 2016 Assessment of Oil and Gas Resources,1 the vast majority of the
Pacific Region’s UERR resources are undiscovered resources that are described as “risked” in
the Draft Proposed Program. Although uncertainty in oil and gas resource estimates is described
generally, it is unclear how uncertainty is quantified and included in the rankings of UERR and
Net Social Value by Planning Area. In California, exploration associated with previous lease
sales in 1963 in Northern and Central California did not lead to the discovery of oil and gas
resources. These failures led to expended capital and environmental impacts that did not result
in any economic or energy benefits. This and other types of risk and uncertainty should be
quantified and incorporated into every step of the valuation process. It is critical that uncertainty
is addressed and reported in a transparent manner to ensure that adequate information is available
to fully evaluate the risk associated with leasing in new areas in the Pacific Region.
1 U.S. Department of the Interior, Bureau of Ocean Energy Management, Pacific Outer Continentatl Shelf
Region, “2016 Assessment of Oil and Gas Resources: Assessment of the Pacific Outer
Continental Shelf Region, ” OCS Report, BOEM 2017-053.
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Second, BOEM’s analysis significantly undervalued the unique and irreplaceable value of
California’s marine ecosystem. California is known for its vibrant and highly productive marine
ecosystem that supports a vast array of sensitive marine species and habitats. California’s
marine environment can be divided into three biogeographic zones: the Oregon border to San
Francisco Bay, from San Francisco Bay to Point Conception and from Point Conception to the
Mexican border. These zones represent an important gradient transitioning from sub-tropical
species in the Southern California Bight to more temperate species in the Pacific Northwest. The
Central Coast is an area of particular interest and marine biodiversity because it serves as a
transition zone between the two areas. California’s coastal areas support several critical habitats
for sensitive marine species, including kelp forests, eelgrass beds, and rocky intertidal habitat.
California’s marine environment supports thousands of valuable marine and coastal species.
Many of these species are considered threatened or endangered under both state and federal laws.
One example is the Southern Sea Otter, a keystone species that is endemic and unique to
California and critical to the maintenance of our kelp forests. The United States Fish and
Wildlife Service estimates that there are only 3000 individuals inhabiting coastal waters between
Half Moon Bay and Point Conception, which constitutes 13% of their historic range.2 The
USFWS considers continued expansion of the Southern Sea Otter’s range critical to recovery of
the species.
Indeed, in recognition of the importance of supporting these vulnerable species, the federal and
state governments have worked in tandem to protect the habitats of many of these species
through the designation of National Marine Sanctuaries and Marine Protected Areas. The State
of California supports four National Marine Sanctuaries (out of 14 total), covering more than
12,000 square miles. The purpose of the Sanctuary system, according to the National Oceanic
and Atmospheric Administration (NOAA), is to “protect America's most iconic natural and
cultural marine resources.”3 In fact, the National Marine Sanctuary Program started in
California with the creation of the Channel Islands National Marine Sanctuary in response to the
devastation caused by the 1969 Santa Barbara Oil Spill. Over the past 20 years, California has
expanded on our treasured National Marine Sanctuary system by establishing a network of
Marine Protected Areas (MPAs), as required under the Marine Life Protection Act enacted by
the California Legislature in 1999. The California Department of Fish and Wildlife was charged
with developing and maintaining the MPA system to “protect the diversity and abundance of
marine life, the habitats they depend on, and the integrity of marine ecosystems.”4 The Coastal
Commission worked closely with CDFW and other state, federal and local agencies, tribal
governments and numerous other stakeholder groups to designate the MPAs in California. The
goals and objectives of the MPA program are in line with requirements of the Coastal Act to
maintain, enhance and restore the biological productivity of coastal waters and marine
organisms. Thus, the Commission has worked to maintain and protect these areas in its role
regulating development in California’s coastal areas. Exposing these valuable areas to
2 U.S. Fish and Wildlife Service: https://www.fws.gov/ventura/endangered/species/info/sso.html
3 NOAA: https://sanctuaries.noaa.gov/about/
4 CDFW: https://www.wildlife.ca.gov/Conservation/Marine/MPAs
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degradation and damage is not consistent with the CCMP, and the ecological importance of these
areas must be factored into BOEM’s analysis of the sensitivity and environmental value of OCS
resources.
BOEM’s initial analysis included in the Draft Proposed Program undervalued the ecological
value of California’s MPAs and the sensitivity of our coastal species and habitats. We are
confident that when California’s coastal resources are appropriately assessed, the economic and
environmental value of maintaining and protecting these resources will outweigh any potential
benefits California may receive from additional oil and gas development.
Third, BOEM’s evaluation failed to adequately account for impacts associated with increased
seismic activity on the reliability of existing and new infrastructure and the risk of an oil spill.
California, Oregon, Washington and parts of Alaska are located in the “Pacific Ring of Fire,”
considered the most seismically active region in the world. According to the USGS, many of
California’s faults have a high likelihood of a medium to major seismic event in the next 30
years. In fact, many of the larger faults are statistically “due” for a moderate to large event. A
seismic event would significantly increase the risk of temporary or permanent damage to
offshore and onshore facilities and increase the likelihood of an oil spill. Furthermore, much of
California’s existing oil and gas infrastructure that any new development would likely rely on
was built before current building standards associated with seismic activity were promulgated
and are now nearing the end of their useful life. This aging infrastructure would be even more
vulnerable to damage or collapse in a seismic event, with the potential for creating significant
hazards to the people and natural environment of California. This information must be factored
into both the economic and environmental assessments of the value of future drilling off of
California’s coast.
Equitable Sharing of Developmental Benefits and Environmental Risks.
Section 18(a) of the OCS Lands Act also requires BOEM to balance the benefits and risks of
offshore oil and gas development in any given region. Comparing the benefits and risks of
additional offshore oil and gas drilling underscores why California is an inappropriate site for
this type of development. California has a long history of oil and gas development both on and
offshore. Our state has been a major contributor to the nation’s oil supplies for over a century.
After reaching peak production in the 1970s and 1980s, California’s crude oil production has
steadily declined over the past 30 years. Despite this decline, California remains the third-largest
oil producing state in the U.S. and ranked third in refining capacity.5
However, the economic and energy-related benefits of this production have been accompanied
by the devastating environmental and economic consequences of oil spills and general habitat
degradation caused by oil exploration and production. California has experienced 3 significant
spills in our coastal areas. Unfortunately, a thorough analysis of the economic and
environmental impacts of older oil spills in California is difficult to find, and we are forced to
5 U.S. Energy Information Administration, California State Profile and Energy Estimates
(https://www.eia.gov/state/analysis.php?sid=CA)
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rely on dollar amounts reached through legal settlements as a proxy for a comprehensive impact
analysis. For example, in 1969, 80,000-100,000 barrels of crude oil were released into the Santa
Barbara channel after a blowout at Union Oil Platform A. The oil spread through the Pacific
Ocean for hundreds of square miles, fouling approximately 40 miles of Southern California’s
coastline and killing approximately 3,600 birds.6 Although the full economic and environmental
impact was difficult to estimate, various class-action law-suits resulted in awards to beachfront
homeowners, boat owners and the State of California, Santa Barbara County, and the Cities of
Santa Barbara and Carpinteria totaling over $17 million.
In 1990, the American Trader, a tanker owned by Attransco and leased by British Petroleum Oil
Shipping Company, spilled an estimated 13,225 barrels into the Pacific Ocean offshore of
Huntington Beach, California. The spill eventually covered over 100 square miles and fouled
several Orange County beaches. Settlement of the case was divided into two parts, recreational
impacts and biological impacts. The biological impacts portion of the case settled out of court
for $3.45 million plus $360,000 for water monitoring projects to mitigate the impacts to fish and
birds (including 3,400 birds that were killed as a result of the spill). The recreational portion of
the case went to trial and a jury awarded state and local governments $18.1 million to mitigate
for lost recreational opportunities during the cleanup and damage to small marine life.
In 1997, an undersea pipeline operated by Torch Operating Company serving platform Irene
offshore of Northern Santa Barbara County ruptured, releasing 163 barrels of crude oil into the
Pacific Ocean. This spill fouled approximately 17 miles of coastline at Surf Beach in
Vandenberg Air Force Base and killed well over 700 birds. The resource trustees settled the
Natural Resource Damages Assessment for $3 million plus over $500,000 in penalties to satisfy
violations of various state and federal laws.
In 2016, the Plains All American Pipeline (“PXP”), which runs parallel to Highway 101,
ruptured near Refugio State Beach, spilling approximately 3400 barrels of crude oil into a ravine.
Approximately 500 barrels of crude reached the ocean and spread into the marine environment.7
Plains estimated the cleanup cost at $100 million, but overall costs, including anticipated legal
claims were estimated at $257 million. The Natural Resource Damage Assessment is still
ongoing, and will be considering impacts to birds, marine mammals, fish, coastal and subtidal
habitats and human uses. The spill also resulted in a significant economic impact to the state and
county for lost tax revenue, federal royalties, worker’s wages and tourism dollars while the
pipeline and the offshore platforms it serves remain shut-in. Commercial and recreational
fishing were also severely affected through the six week closure of 138 square miles of fisheries
as a direct result of the spill.6
6 County of Santa Barbara Planning and Development, Energy Division:
http://www.sbcountyplanning.org/energy/information/1969blowout.asp
7 CDFW: https://www.wildlife.ca.gov/OSPR/Science/Laboratories/Chemistry/Special-
Projects/Fishery-Closure
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These spills illustrate the enormous environmental and economic risks to coastal and marine
populations and resources from spills associated with onshore and offshore oil and gas
infrastructure. Although BOEM did not classify the 1969 oil spill as “catastrophic” in the Draft
Proposed Program, millions of Californians who lived through the spill and endured its aftermath
would disagree. It is important to point out that although BOEM describes a catastrophic spill as
“not expected” and “well outside the normal range of probability,” and thus does not include the
risk and impact of this type of spill in its calculation of social cost of new oil development, the
U.S. has experienced two catastrophic spills in the last 30 years, and three catastrophic spills in
the last 50 years if the 1969 Santa Barbara spill is counted. Given this occurrence rate, it is not
realistic to treat these types of spills as “not expected.” BOEM appears to discount the
likelihood of catastrophic spills in part because of newer safety regulations, but the PXP spill
occurred just two years ago, and much of California’s oil and gas production infrastructure is
aging, increasing the likelihood of a catastrophic spill. To fully assess the social cost of new oil
and gas development, BOEM must include a thorough analysis of the risk and impacts from the
worst-case spill, in addition to the higher-frequency, low volume spill. Oil spills pose a serious
threat to California’s coastal resources. The Commission’s experience with the consequences of
an oil spill will factor heavily in its analysis of the consistency of new offshore leases with the
enforceable policies of the CCMP.
In addition to the risk of a catastrophic oil spill, impacts from day to day oil and gas operations
pose a significant environmental risk to coastal resources. Construction and operation of oil and
gas platforms are likely to result in adverse impacts to sensitive marine habitats and species,
water quality, commercial and recreational fishing, visual resources, tribal and cultural resources,
and public access and enjoyment of California’s coastal zone, all resources protected under the
Coastal Act. Furthermore, due to the uncertain nature of California’s offshore oil reserves, any
new development is likely to necessitate seismic surveys to conclusively map the ocean floor and
better define the location of oil and gas reserves. Seismic surveys have the potential to result in a
multitude of impacts to marine mammals, fish and other marine organisms. Degradation of
water quality from direct discharge of produced water and drilling muds is also a significant
environmental risk.
Finally, as BOEM assesses the costs and benefits of new oil and gas development in the OCS, it
is critical that the full cost of decommissioning offshore platforms be included in the assessment.
Many of California’s existing offshore platforms are nearing the end of their useful production
life (estimated to occur between now and 2030). However, as noted in a 2010 study published
by the Ocean Science Trust, significant data gaps exist that prevent the full quantification of
impacts and costs. 8 In 2017, in the aftermath of the Refugio oil spill, Venoco, Inc. filed for
bankruptcy, quitclaiming its offshore leases and abandoning its obligation to decommission
Platform Holly and its associated onshore facilities. As the landowner, the responsibility to
decommission Platform Holly fell to the State Lands Commission. Decommissioning costs, the
majority of which will be borne by California’s taxpayers, are estimated to be a minimum of 125
8 California Ocean Science Trust, “Evaluating Alternatives for Decommissioning California’s Offshore Oil and Gas
Platforms: A Technical Analysis to Inform State Policy. June 2010.
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million dollars9. In the past, costs and impacts of decommissioning have not been adequately
quantified when a new facility is developed, leading to insufficient performance bonds and
inadequate protection for the landowner. To avoid this scenario and to accurately assess the
benefits and environmental risks associated with new offshore drilling, BOEM should
thoroughly analyze and quantify all costs associated with decommissioning and factor these costs
into the overall feasibility analysis to inform future leasing decisions.
Location with Respect to Regional and National Energy Markets and Needs
A third factor that BOEM is required to consider is the location of offshore oil and gas
development in relation to a region’s energy markets and needs. However, there is no reasonable
basis to conclude that either California or the U.S. needs more offshore drilling. To the contrary,
recent energy analysis, scientific research and state policy point away from any expansion of
offshore oil and gas activities in California. California’s energy markets and needs have
dramatically changed since its 23 federal offshore platforms were first approved. As BOEM is
aware, the State of California is committed to moving away from reliance on fossil fuels and
towards renewable sources to meet the State’s energy needs. First established in 2002 under
Senate Bill 1078, California’s Renewables Portfolio Standard (“RPS”) establishes ambitious
goals to reduce the State’s emissions of greenhouse gases in an effort to combat climate change.
These goals include reducing greenhouse gas emission to 40% below 1990 levels by 2030 and
80% below 1990 levels by 2050. These reductions are to be achieved through requirements that
renewable source of energy account for 33% of all electricity generation by 2020 and 50% by
2030. To meet these goals, California is aggressively pursuing development of renewable
sources of energy including solar thermal, solar photovoltaic, wind, geothermal, biomass and
small hydroelectric to replace oil and gas.10 In 2015 Governor Brown established a goal to
reduce current petroleum use in cars by up to 50% in 2030. A direct result of these policies is
that California’s current and projected needs for fossil fuels are rapidly declining. As
California’s demand for petroleum products declines, the most likely scenario is that additional
oil and gas produced from new federal leases is likely to be exported outside the state.
Furthermore, as noted in the Draft Proposed Program, California’s refineries are already
operating at or near maximum capacity due to the high demand for the types of petroleum
products they produce. Additional OCS production would create the need for additional refinery
capacity in California that may be difficult to achieve given political and regulatory constraints.
The likely result is that new offshore oil and gas production in California would be exported,
thus increasing costs of getting the product to market, as well as increasing the risks of
environmental damage associated with transportation of oil and gas.
9 State Lands Commission staff report, “Consider Acknowledgement of the Commission’s Ongoing
Actions to Ensure the Safety of Offshore Oil and Gas Lease Nos. PRC 421.1, PRC 3120.1, PRC 3242.1, amd
Provide a Status Update Relating to Venoco, LLC’s Chapter 11 Bankruptcy, Offshore Santa Barbara
County, June 22, 2017.
10 California Energy Commission – Tracking Progress: http://www.energy.ca.gov/renewables/
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Finally, as a consequence of the Refugio oil spill, the PXP pipeline that transports oil from
offshore platforms inland for processing is currently shut-in. As a result, several offshore
platforms that rely on this pipeline, including Platforms Heritage, Harmony and Hondo and
Platforms Hidalgo, Hermosa and Harvest have been forced to shut down production until the
pipeline is either repaired or rebuilt. There is no current timeline for this endeavor, although it is
worthwhile to note that either repairing or replacing the PXP pipeline is a major undertaking that
will face numerous regulatory hurdles. It is also likely that the pipeline will be subject to new
monitoring and maintenance requirements that could increase the cost of operating the pipeline.
These facts should inform an analysis of the feasibility of transporting additional oil products
onshore in areas served by the PXP pipeline.
Each of the issues raised above supports a conclusion that new offshore production in California
is not likely to be used to meet the State’s energy needs. Instead, oil and gas produced offshore
of California is likely to be transported some distance out of state or out of the country to reach
its intended market. This scenario both decreases the benefits California would receive from any
new oil and gas production and increases the environmental risks associated with transportation
of oil and gas. This is in direct conflict with BOEM’s charge to balance the benefits and risks of
offshore oil and gas development (Section 18(a)(B) of the OCS Lands Act), and thus further
supports the conclusion that California is not a suitable location for additional offshore oil and
gas drilling.
Location with Respect to Other Uses of the Sea and Seabed
A fourth factor BOEM is required to consider under Section 18(a) of the OCS Lands Act is other
potentially conflicting uses of the sea and seabed in the OCS. While there are too many such
uses to fully document in this letter, it is evident that the preliminary assessment did not
adequately consider the complexity and importance of the existing uses of California’s OCS.
California’s offshore environment is extremely active, with many different uses competing for
space and resources. Aside the from the above-mentioned protection of the offshore
environment for marine species and habitats, other significant uses of the OCS that could conflict
with additional offshore oil and gas development include commercial and recreational fishing,
aquaculture, offshore renewable energy, tourism and recreation, military operations including
training and testing, marine transportation, and telecommunications. It is critical that BOEM
fully evaluate the economic, social and environmental costs and potential impacts to these
sectors from additional oil and gas development in California’s OCS.
Commercial and Recreational Fishing
California supports more than 20 distinct fisheries and numerous fishing communities. Although
fishing has been a constant presence in California, “the mix of fisheries and level of activity in
each port and regionally varies as a function of changes in species distribution and availability,
market demand, regulations, physical infrastructure, buyers and other factors (California Sea
Grant).”11 For example, as noted in the Draft Proposed Program, Southern California Fisheries
11 Sea Grant California, Discover California Commercial Fisheries:
https://caseagrant.ucsd.edu/project/discover-california-commercial-fisheries
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generally contribute a larger share of California’s total fish landings by pound. However, in
recent years, the North Coast and North Central California fisheries have contributed a larger
share of California’s fish landings when measured in dollars. This phenomenon is largely due to
the focus on species with a higher price per pound, such as Dungeness crab and Chinook salmon,
in the northern portions of the State.10 BOEM’s initial conclusion that commercial fisheries are
an important use in Southern but not Northern or Central California, conflicts with these data. In
addition, because this preliminary analysis relied on data from 2009, it also did not capture
changes in commercial fishing that have occurred since 2009. As one example, a 2015 report by
Lisa Wise Consulting Group cited steady growth in the Morro Bay fisheries since a low in
2007.12 According to the report, “Morro Bay has successfully transitioned from a larger fleet
reliant on trawl and large volumes of landings to a smaller fleet profile with a wide diversity of
species and gear types. This is evidenced by the seventh year of growth in earnings from a 25-
year low in 2007. 2015 is the strongest year in the last 20.” This information supports a
conclusion that commercial fishing is a significant and important use in all California Planning
Areas and should be included in future analyses of competing uses in the OCS. Furthermore,
fishing is protected under the Coastal Act and will certainly be included as a factor in any future
analysis of the consistency of new offshore leasing and development with the CCMP.
Aquaculture
Aquaculture is becoming an increasingly important priority use in California’s state and OCS
waters. California currently supports three existing open ocean operations comprising over 125
acres, and an additional four projects covering roughly 2,300 acres, almost entirely within federal
waters, are currently undergoing regulatory review. There are a variety of efforts and policies at
both the state and federal level directed at protecting and expanding marine aquaculture within
state and federal waters offshore of California. For example, California’s Aquaculture
Development Act (Public Resources Code, Sections 826-828) encourages the practice of
aquaculture to augment food supplies, expand employment and promote economic activity
within the marine sector and protect and better use the land and water resources of the state.
NOAA’s National Shellfish Initiative (2013) and the National Marine Aquaculture Policy (2011)
seek to increase populations of bivalves in coastal waters through commercial aquaculture
production. These two federal policies explicitly acknowledge the multiple benefits of shellfish
aquaculture, including its ability to provide new jobs and business opportunities and help meet
the growing demand for seafood. Additionally, both the NOAA Sea Grant Program and the U.S.
Department of Energy’s Advanced Research Projects Agency (ARPA-E) are actively funding
efforts to develop and expand commercial and industrial scale aquaculture operations offshore of
California to produce shellfish and marine algae for use as food and source material for the
production of bio-fuels.
Many of the locations that currently support existing marine aquaculture facilities and/or areas
targeted for expansion of marine aquaculture, including areas offshore of Point Loma (San
Diego) and portions of the Santa Barbara Channel and San Pedro Shelf (offshore of Long
12 Lisa Wise Consulting, “Morro Bay Commercial Fisheries: 2015 Economic Impact Report, Working
Waterfront Edition,” July 2015.
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Beach), could be adversely affected by additional offshore leasing, surveying and development.
Several specific projects have invested several years into planning and permitting and involved
substantial federal funding and research support. These projects include the proposed doubling
in size of the Catalina Sea Ranch facility located on the San Pedro Shelf portion of the OCS, the
proposed tripling in size of the Santa Barbara Mariculture facility located within the Santa
Barbara Channel, the 2,000 acre Ventura Shellfish Enterprise within the Santa Barbara Channel
and the more than 100 acre Rose Canyon Fisheries project in federal waters off San Diego.
Renewable Energy
In an effort to meet the ambitious RPS standards set by the Governor and legislature and
described in more detail above, California has been actively pursuing the development of
renewable energy sources statewide. An important component of the state’s plan to supply 50%
of the state’s electricity from renewable resources by 2030 is the development of offshore wind
resources. After BOEM received an unsolicited lease request from a developer interested in
constructing an offshore wind farm off of California’s Central Coast, California’s governor and
the U.S. Secretary of the Interior signed an MOU forming the BOEM California
Intergovernmental Renewable Energy Task Force (Taskforce). This taskforce, of which the
Commission is a member, is described in the BOEM Interim Outreach Summary Report as a
“partnership of members of state, local and federally-recognized tribal governments and federal
agencies to provide critical information to the decision-making process for planning future
offshore renewable energy development opportunities in federal waters offshore California.”
Since the Taskforce was established in May of 2016, both state and federal agencies have
devoted significant resources into outreach and engagement efforts as well as gathering data to
inform analysis of the siting and design of potential offshore wind installations in California.
Since the initial unsolicited request for a lease off of the Central Coast, additional offshore wind
developers have come forward with interest in leasing OCS waters off of the North Coast.
Part of the impetus behind the interest in offshore wind stemmed from a study published in
December 2016 by the National Renewable Energy Laboratory entitled “Potential Offshore
Wind Energy Areas in California: An Assessment of Locations, Technology and Cost.” The
study identified 112 Gigawatts (“GW”) of technical offshore wind resource potential over the
entire California coastline, or approximately 1.5 times the total electricity consumption of the
state in 2014. The study also identified an emerging market in floating wind turbines worldwide
with expected commercial development in 2025. This is significant because it is expected that
any offshore wind installations in California will deploy floating wind technology. The results
of the 2016 NREL study when coupled with developer interest and California’s ambitious
renewable energy goals indicate that offshore renewable energy is a significant and credible
potential future use of the California OCS that should be factored in to BOEM’s analysis of
additional offshore oil and gas development in California. In addition, offshore wave energy,
although not as well developed as offshore wind energy, should also be considered as a
competing use of OCS waters in California.
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Tourism and Recreation
California’s beaches and ocean-based recreation are a major draw for both in and out-of-state
visitors. Visitors come to surf, swim, walk on the beach, sight-see, kayak, fish or enjoy a
multitude of other activities along California’s beautiful coastline. One of the principal policies
of the Coastal Act preserves the public’s right to access and enjoy the beach and surrounding
marine areas. In 2016, NOAA released a report called “The National Significance of
California’s Ocean Economy” that sought to quantify the importance of California’s marine
transportation and ocean tourism sectors. According to the report, tourism and recreation in
California’s coastal areas accounted for 39 percent of the California ocean economy’s GDP
($17.6 billion), 75 percent of its employment (368,000), and 46 percent of its wages paid ($8.7
billion) in 2012, making it the largest of California’s six ocean dependent sectors. To compare
California’s ocean-based tourism and recreation sector to the rest of the country, in 2012, it
included more than 18,000 business establishments (15 percent of U.S. total), employed almost
368,000 persons (18 percent of the U.S. total) and generated $8.7 billion in wages (19 percent of
the U.S. total) and more than $17.6 billion in GDP (18 percent of the U.S. total).” These data
demonstrate the economic importance of California’s ocean-based tourism and recreation to our
state and to the nation. Putting these valuable resources at risk with additional offshore oil and
gas development is counter to the Coastal Commission’s charge to protect public access and
recreation in California’s coastal zone, and is not in the interest of Californians, or any other
American or foreign visitors to California’s coast.
Military
As the Draft Proposed Program notes, the Department of Defense (DoD) uses the OCS airspace,
sea surface, subsurface and seafloor for military training, testing and operations. In an initial
assessment of military conflicts with potential offshore wind development siting areas, DoD
indicated that the entire Central and Southern California OCS should be excluded from future
wind development because of the high level of military activity currently in these areas. Given
recent increases in the DoD budget, it is likely that military operations in the OCS will increase.
Although offshore wind development and oil and gas development are not identical in scale or
use of OCS waters, the same conflicts DoD raised related to offshore wind development are
likely to apply to offshore oil and gas development. Close coordination with DoD will be critical
in quantifying the potential conflicts with current and future military use of the OCS.
Marine Transportation and Telecommunications
Finally, marine transportation and telecommunications are important uses of the OCS that could
pose a conflict with additional OCS oil and gas development. According to the 2016 NOAA
report, marine transportation is the second largest of California’s six ocean-dependent economic
sectors, accounting for 31 percent of the ocean-dependent GDP in 2012 ($14.1 billion).
California’s ports are also a critical component of the U.S. economy, accounting for about a
quarter of the U.S. marine transportation sector for wages and GDP, approximately 17% for
number of establishments and 22% for employment in 2012. Our ports serve as a gateway for
the entire U.S., with California leading the nation in the monetary value of both imports and
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exports. Any additional oil and gas development could impact the marine transportation industry
through direct space conflicts offshore and in the Ports, additional boat traffic, and the risks
associated with an offshore oil spill.
Since the early 1990’s California has authorized the installation and operation of 12 fiber optic
cable systems in state and federal waters in the OCS. These cables connect the United States to
various locations along the western rim of the Pacific Ocean to facilitate data networking and
telecommunications. According to industry representatives, there is high demand for additional
cables to ensure a diverse and reliable network.13 In addition to the cable systems already
authorized, several more are in the planning stages. These cable systems could pose a conflict
with additional offshore oil and gas development through direct space conflicts as well as
conflicts associated with additional boat traffic, and should be thoroughly addressed in BOEM’s
analysis.
Laws, Goals and Policies of Affected States identified by the Governors
The fifth factor includes consideration of the laws, goals and policies of affected States.
California has enacted several laws, goals and policies that oppose additional oil and gas
development in California’s offshore environment, several of which are discussed in this letter.
In addition to state laws and policies, several local governments have passed ordinances
opposing onshore facilities that support offshore oil and gas infrastructure. However, in this
section we will focus on the California Coastal Act, which will serve as the standard of review
for any future federal consistency analysis for activities on the OCS. Chapter 3 of the Coastal
Act contains the principal enforceable policies that the Coastal Commission relies upon to
evaluate development in the Coastal Zone, or outside the Coastal Zone in certain circumstances.
Although Chapter 3 includes a multitude of policies, the main sections that the Commission will
use to assess offshore oil and gas drilling are (1) 30210 Access; recreational opportunities;
posting, (2) 30220 Protection of certain water-oriented activities, (3) 30222.5 – Aquaculture
facilities, priority use, (4) 30230 - Marine resources and fishing, (5) 30231 – Biological
productivity; water quality, (6) 30232 – Oil and hazardous substance spills, (7) 30234.5 –
Economic, commercial and recreational importance of fishing, (8) 30244 Archeological or
paleontological resources, (9) 30250 – Cumulative impacts, concentration of development, (10)
30251 – Scenic and visual qualities, (11) 30253 – Minimization of geologic hazards, protection
of air quality, minimizing energy consumption, and protection of visitor destinations, (12) 30260
– Coastal dependent industrial development, consideration of the public welfare, (13) 30261 –
Multicompany use of tanker facilities, (14) 30262 – Oil and gas development, and (15) 30265
Legislative findings and declarations; offshore oil transportation. The overall theme running
through these Coastal Act policies is the protection of coastal resources. Additional offshore oil
and gas development would conflict with many of these policies, thus supporting the conclusion
that California is not a suitable location for additional offshore leasing.
13 California Coastal Commission staff report for A-5-DRL-17-0071/9-17-0389/CC-0004-17(Tyco
Electronics Subsea Communications), February 5, 2018
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Relative Environmental Sensitivity and Marine Productivity
The OCS Lands Act also requires BOEM to consider the relative environmental sensitivity and
marine productivity of the OCS regions. Once again, application of this factor to California’s
offshore environment undermines rather than supports the case for additional offshore drilling
off California. As described above, California’s offshore environment is highly productive and
supports a wide variety of unique and sensitive species and habitats. The sensitivity of
California’s marine and coastal ecosystems to climate change and the effects of climate change
(i.e., sea level rise, ocean acidification, rising temperatures, changing weather patterns, saltwater
intrusion, etc.) is well documented and a continued source of study. Thus, California’s low
relative environmental sensitivity score as reported in the Draft Proposed Program was
surprising. However, the lack of a full explanation of the methodologies and data sources used
to calculate the relative environmental sensitivity score makes it difficult to provide substantive
comments. From the information that was provided, it appears that BOEM’s assessment of
California’s environmental sensitivity was based on an extremely small set of species and
habitats. Selection of those species and habitats was based on application of a very limited set of
criteria to large scale datasets and very little California-specific information. The resultant
scores are highly dependent on the species and habitats selected and are not intended to be
representative across the state. As a result, the final environmental sensitivity score does not
accurately capture the complexity and vulnerability of California’s coastal and marine
ecosystems. More generally, regardless of the relative environmental sensitivity score BOEM
assigns to California, additional offshore oil and gas development would pose an unacceptable
risk of harm to the already stressed species and habitats of California’s coastal and marine
environment.
Environmental and Predictive Information
Finally, we want to address the last factor in BOEM’s analysis: environmental and predictive
information. Most of the environmental factors that we believe BOEM should consider in its
analysis of future leasing areas have been discussed above. However, impacts associated with
new offshore drilling also have the potential degrade or destroy tribal and cultural resources. In
California, as in other coastal states, coastal areas, both on and offshore, have a high potential to
contain valuable tribal, cultural, or historical resources that may not be known or mapped. To
ensure these resources are adequately protected, BOEM has an obligation to conduct
government-to-government consultations with all federally-recognized tribes, as well as to
strongly consider consultations with non-federally recognized tribes. If new leasing areas are
proposed off California, as part of the Commission’s federal consistency process, Commission
staff will reach out to both federally- and state-recognized tribes to gain a better understanding of
potential conflicts with known and unknown tribal resources in a given area.
Oil and gas development in the United States is not just about economic and ecological tradeoffs;
there are also significant environmental justice implications for the communities most affected
by development activities. We urge BOEM to consider issues of environmental justice in its
analysis and decision-making regarding new leasing areas and the eventual development these
lease areas will support. The Commission is dedicated to incorporating environmental justice
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into its evaluation of development under the Coastal Act, and will include analysis of impacts to
low-income communities and communities of color in any future federal consistency
determinations for new offshore oil and gas leases.
Conclusion
In sum, we fully support the request of our Governor, our Chair and the united voice of
California’s resource agencies to remove California from further consideration for new offshore
oil and gas leasing. We were extremely disappointed to see BOEM held only a single cursory
briefing in Sacramento for a matter of such strong significance to all Californians. If BOEM
intends to persist in efforts to lease the California OCS, we could not more strongly urge BOEM
to hold a series of public meetings, at least one in each region of our state, to allow the citizens of
California an opportunity to express their views on expanded offshore oil and gas drilling off
California’s coast.
Sincerely,
JOHN AINSWORTH
Executive Director
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STATE OF CALIFORNIA—NATURAL RESOURCES AGENCY EDMUND G BROWN, G OVERNOR
CALIFORNIA COASTAL COMMISSION
45 FREMONT, SUITE 2000
SAN FRANCISCO, CA 94105-2219
VOICE AND TDD (415) 904-5200
FAX (415) 904-5400
March 9, 2018
Ms. Kelly Hammerle
National Oil and Gas Leasing Program Development and Coordination Branch
Leasing Division
Office of Strategic Resources
Bureau of Ocean Energy Management (BOEM) (VAM-LD)
45600 Woodland Road
Sterling, Virginia 20166-9216
RE: Comments on the 2019-2024 Draft Proposed National Oil and Gas Leasing Program
(Docket ID: BOEM-2017-0074)
Dear Ms. Hammerle:
As stated in a February 7, 2018 letter from the Chair and a March 7, 2018 letter from the Executive
Director of the California Coastal Commission (“Commission”), the Commission strongly opposes
additional lease sales in California’s Outer Continental Shelf (“OCS”) planning areas and requests
that California be removed from consideration for additional offshore oil and gas development in
the 2019-2024 Proposed National Oil and Gas Leasing Program (“Proposed Program”). However,
if California is included in the Proposed Program, the Commission submits the following scoping
comments on the Draft Environmental Impact Statement (“EIS”) that will accompany the Proposed
Program.
In its role implementing California’s federally approved coastal management program, the
Commission will conduct a federal consistency review to determine the consistency of any
proposed lease sales, exploration, and production plans, and associated activities in federal waters
with the enforceable policies of the California Coastal Act. Potential Coastal Act issues raised by
the Proposed Program include: siting of hazardous industrial development; seismic and subsidence
hazards; oil spills and release of other hazardous materials; water and air quality; greenhouse gas
emissions; noise; visual impacts; recreation and public access; cultural resources; wetlands and
other environmentally sensitive habitats; marine resources; and cumulative impacts. The
Commission will rely in part on the information contained in the EIS in assessing the conformity of
these activities with the Chapter 3 coastal resource protection policies.
To assist us in our review of proposed program elements, we request that the EIS specifically
address the following:
1. General:
a. Cumulative Impacts: The EIS should include analysis of the cumulative impacts
associated with the maximum extent of oil and gas development from leasing of all
planning areas included in the Draft Program. The EIS should also include an analysis
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of the cumulative impacts associated with both proposed and existing oil and gas
activities in the OCS.
b. Alternatives: The EIS should include analysis of a full set of feasible alternatives for
additional oil and gas development on the OCS, including, at a minimum, an alternative
that excludes California from the 2019-2024 leasing program.
2. Activities: At a minimum, the EIS should analyze impacts associated with the following
activities associated with offshore oil and gas development:
a. Exploration
i. Seismic and other geophysical studies
ii. Drilling exploratory wells
iii. Onshore and offshore infrastructure needed to support exploration
b. Development
i. Construction of platforms, pipelines, onshore and offshore facilities for
processing, refining, transportation or storage of oil and gas products
ii. Drilling of wells
iii. Other onshore or offshore infrastructure needed to support oil and gas
development
c. Production
i. Operation and maintenance of wells, platforms, pipelines, processing and storage
facilities, refining facilities
ii. Hydraulic fracturing
iii. Handling of waste and wastewater
iv. Transportation of crude and/or processed oil and gas to its final destination
d. Decommissioning
i. Plugging and abandonment of wells
ii. Removal of structures including platforms, pipelines and onshore processing or
refining facilities
iii. Restoration of impacted areas
e. Oil spills
i. Catastrophic or large spills
ii. Small spills
iii. Clean-up activities
iv. Cumulative impacts
3. Potentially Affected Coastal Resources: At a minimum, the EIS should analyze potential
impacts (temporary and permanent) to the following coastal resources:
a. Public Access and Recreation:1 The EIS should include an analysis of impacts to public
access and recreation for visitors, businesses, and local and state governments including
impacts related to:
i. Temporary or permanent loss of public access or recreation opportunities
1 Articles 2 and 3 of the Coastal Act protect public access and recreation on California’s coast. Section 30251
protects the scenic and visual qualities of coastal areas.
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ii. Traffic – onshore and offshore
iii. Noise
iv. Vibration
v. Visual Landscape/Aesthetics
b. Marine and coastal habitats and species: 2 At a minimum, the EIS should include an
analysis of impacts to marine habitats and species related to:
i. Sensitive species, including federally and state listed species
ii. Loss and/or degradation of sensitive habitat (including, but not limited to
intertidal or subtidal hard substrate, eelgrass beds, kelp forest, sand dollar beds,
deepwater coral, Essential Fish Habitat, coastal wetlands and estuaries, beaches,
dunes)
iii. Marine sanctuaries and other protected areas
iv. Ship strikes and other impacts associated with increased boat traffic
v. Oil Spills, including:
1. Catastrophic spill (similar or larger than the 1969 Santa Barbara spill)
2. Large spills (≥1000 barrels)
3. Small spills (<1000 barrels)
4. Cumulative impacts from multiple spills at a time (i.e., due to a major
seismic event) and cumulative impacts to areas that have experienced
previous spills
vi. Noise (above and under the water surface)
vii. Lighting
viii. Vibration
ix. Water quality (i.e., impacts from routine discharges of produced water, drilling
muds, sanitary wastes and other platform wastewater, turbidity, ship waste, etc.)
x. Air quality including greenhouse gas emissions
xi. Invasive species
xii. Erosion from terrestrial activities 3
c. Space-Use Conflicts
i. Offshore
1. Renewable energy
2. Commercial and recreational fishing 4
3. Recreation
2 Sections 30230 and 30231 of the Coastal Act require that marine resources be maintained, enhanced and
where feasible, restored and that the biological productivity and quality of coastal waters appropriate to
maintain optimal populations of marine organisms and for the protection of human health be maintained
and, where feasible, restored. Section 30240 of the Coastal Act protects environmentally sensitive habitat
areas from any significant disruption of habitat values and requires development adjacent to
environmentally sensitive areas to sited and designed to prevent impacts to those areas. ). Section 30232
states that protection against the spillage of crude oil, gas, petroleum products or hazardous. Section 30233
defines the circumstances in which wetlands and open coastal waterscan be filled, dredged, or diked.
3 Section 30253 of the Coastal Act states that new development shall not create nor contribute significantly to
erosion.
4 Sections 30234 and 30234.5 of the Coastal Act protect fishing activities and infrastructure.
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4. Tribal and cultural uses 5
5. Military
6. Shipping/commerce
7. Telecommunications
8. Aquaculture 6
ii. Onshore - conflicts with existing or planned land uses with onshore infrastructure
needed to facilitate additional offshore oil and gas development
d. Commercial and Recreational Fishing 7
i. Exclusion
ii. Degraded water quality and fish/benthic habitat
iii. Additional boat traffic
e. Hazards 8
i. Erosion
ii. Subsidence
iii. Induced seismicity
iv. Risk of blowouts or other unplanned occurrences
f. Tribal and Cultural Resources 9: BOEM should conduct consultations with both federal
and state-recognized tribes
g. Environmental Justice 10: The EIS should analyze to what extent additional offshore oil
and gas development could disproportionally impact low-income communities or
communities of color.
We appreciate the opportunity to provide these scoping comments on the draft EIS. We sincerely
hope that BOEM defers to the wishes of our Governor and the united voice of California’s resource
agencies to remove California from the 2019-2024 Proposed Program. If BOEM does include
California in the Proposed Program and the draft EIS, we again request that BOEM hold a series of
public meetings, at least one in each region of our state, to allow the citizens of California an
opportunity to express their views on expanded offshore oil and gas drilling off California’s coast.
Sincerely,
(for) ALISON DETTMER
Deputy Director
5 Section 30244 of the Coastal Act protects archeological and paleontological resources.
6 Section 30222.5 of the Coastal Act protects oceanfront land suitable for aquaculture.
7 See footnote 4
8 See footnote 3
9 See footnote 5
10 Section 30013 of the Coastal Act requires the no person in the State of California shall be discriminated
against or denied access to the protections and benefits of the Coastal Act on the basis of race, national
origin, ethnic group identification, religion, age, sex, sexual orientation, color, genetic information or
disability.
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