CRE Seeks Comments on its Proposed Comments to MMS on OCS Leasing Program

Attached are CRE’s proposed comments to MMS on its Proposed 5-Year Outer Continental Shelf (OCS) Oil and Gas Leasing Program for 2010-2015 (DPP).

We call your particular attention to our conclusion that seismic operations have de minimis impact on marine mammals, see Section II , pg. 8 “ Oil and Gas Seismic Operations Do Not Affect Sperm Whale Foraging”

 For those of you interested in the encroachment of marine protected areas on OCS development and our conclusions that the OCS Act trumps marine protected area concerns, please see Section I  pg. 2,  “Analysis of Environmental Impacts under the OCSLA; Interpretation of the “Avoid Harm” Provision of E.O. 13158  on Marine Protected Areas (“MPAs”).”

Peer Reviews of CRE Work Products are in the Discussion Forum

Visit the Discussion Forum of this IPD  to review  expert reviews of CRE work products. The reviews are in the Discussion Forum of this IPD and are accessible throught the “Discussion Forum” in the upper right hand corner of this page.

The public is encouraged to express its views–all posting are anonymous unless you type in your name.

US government regulatory agencies  have a virtual monopoly over regulatory dockets since they are open for only a limited period of time for public comment.  CREs Interactive Public Dockets are aimed at breaking this monopoly.

The Implications of the NOAA National System of Marine Protected Areas on the Outer Continental Shelf Lands Act

CRE invites public comment on the following paper, attached hereto, which will provide one basis for CRE supplying comments to MMS on its five year OCS program.

Short comments can be submitted by clicking on comments above; more detailed comments, particularly if there is an attachment thereto, should be presented as a separate submission by “Submit a Post” on the Discussion Forum.

You can append an attachment to your separate submission by clicking on “Browse” on the Discussion Forum, which will allow you to download a file from your documents section.

Please comment on the Attachment below: MMS Five Year Plan Conflict

Updating a Government Report 24/7

The  federal government routinely issues reports on a wide variety of issues. Federal agencies often request public comments on a draft report prior to issuing it in final form.

Why not allow the public to update the report on a 24/7 time schedule?  The federal government would benefit from  public comments on comments submitted on the draft report as  well as having  a data base for subsequent revisions of the  report.