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”).”

 We would appreciate your posting your comments on the above article at  http://www.thecre.com/zoning-forum/  Merely type in your comments  under “Submit Post” and then press “Send”– feel free to attach supporting studies. All comments are  anonymous unless you provide personal identifiers.

CRE is going to post the comments it submits to MMS, as well as those of other  “influential” stakeholders, on the Interactive Public Docket (IPD) at http://www.thecre.com/creipd/  . CRE will then request that stakeholders submit reply comments to the comments submitted by other stakeholders on the IPD. A analysis of  reply  comments will be forwarded to MMS

Center for Regulatory Effectiveness

MMS OCS Comments