Wed. 4/24: That would be a “NO” on “streamlining” environmental devastation, Wilbur… Deadline Thursday 4/25, 11:59 pm EST.

People – this only has 3088 comments – most of which will be tossed for duplication!

This sly little rule change will gut our states abilities to stop offshore drilling!

The Trump administration, through NOAA (now controlled by Wilbur Ross, our incredibly corrupt Secretary of Commerce) would like to “streamline” the “federal consistency process” in the Coastal Zone Management Act (CZMA) affecting offshore oil and gas. This regulatory proposal would weaken long-held state’s rights with respect to virtually all facets of federal offshore oil and gas drilling, seismic airgun petroleum exploration, and renewable energy projects.

CZMA, passed in 1972 after the devastating 1969 Santa Barbara oil spill, is widely considered one of the most powerful tools states have to regulate activity off their coasts. It applies to all of the coastal and Great Lakes states, with the exception of Alaska. The act assures that drilling, shipping, commercial fishing, mineral extraction, wind power projects and other activities fit into states’ plans for protecting their coastal zones, even activities that occur outside a state’s jurisdiction, which extends three miles from the coast, and allows for public scrutiny and the creation of local environmental impact statements. 

Using the Act, CA stopped 36 controversial oil leases between Monterey Bay and Channel Islands national marine sanctuaries as well as a 2007 proposal for a liquefied natural gas port, planned for a site 14 miles offshore from Ventura and LA counties. 

This regulatory proposal is a first step to weakening our defenses to Trump’s ridiculous energy dominance plan, which opens up 90% of the United States coastlines to oil and gas productions (with the exception of the Arctic Ocean and an area of underwater canyon off the Atlantic coast). CA and other states have already passed laws prohibiting new oil and gas pipelines, to make transporting oil prohibitively expensive. The CA Coastal Commission is already planning to fight back against the administration’s lease program, but this “streamlining” proposal could reduce their power. So write a comment and make sure your friends and family do too.

Read the proposed rule here. Talking points and sample comments immediately below, background info. at the bottom.

COMMENT HERE!

Talking points

This piece of regulatory shenanigans asks three questions…

1. What changes could be made to NOAA’s federal consistency regulations… that could streamline federal consistency reviews and provide industry with greater predictability when making large investments in offshore renewable and non-renewable energy development? 

Answer: Come back to us after you remove “non-renewable energy” from the equation. States have already spoken clearly on that issue. We are not interested in reducing the opportunity for public scrutiny of any potential threats to our coastline.

2. NOAA is seeking comments on whether and how NOAA could achieve greater efficiency to process an appeal in less time and increase predictability in the outcome of an appeal—while continuing to meet the requirements and purposes of the Coastal Zone Management Act (CZMA)…

Answer: It will take almost no time and be 100% predictable to say “NO” to all “non-renewable energy” propositions. Other than that, we demand that our CZMA plans be honored in their entirety.

3. When an applicant seeks Secretarial review of a state CZMA federal consistency objection, the CZMA requires the Secretary to collect appeal fees from the applicant.  The fees include an “application fee of not less than $200 for minor appeals and not less than $500 for major appeals, unless the Secretary, upon consideration of an applicant’s request for a fee waiver, determines that the applicant is unable to pay the fee.” …

Answer: Seriously? Are we talking about waivers for those who can’t afford a $500 appeal fee? For an activity where oil spills are not only inevitable , but cost millions or even billions to clean up? See answers #1 and 2.

More talking points.

• States should be able to challenge federal government actions that undermine their own coastal zone management plans.
• It is critical that states have power over their valuable coastal resources.
• The state’s consistency review process provides a key opportunity for the public to participate in decisions impacting coastal resources and economies.
• I oppose the weakening of federal consistency under the CZMA as it relates to any relevant federal action affecting California’s Coastal Zone.
• Don’t undercut California’s integral role in coastal decision-making.
• Check out the “Background” section at the bottom for more interesting information to add to your comments.

Example comments from the regulatory site.

Note: Of the 3088 existing comments, most will be thrown out for being exact duplicates! There are a lot of exact copies in here of what we call “Comment X” (down at the bottom of the comments). So channel your creative writing class from 7th grade and change things up.

Comment: Read this from the NH Dept. of Environmental Services

Comment: NO “STREAMLINING” to make it easier for OIL companies to drill offshore! If greedy corporations have their way, our shores will be covered with oil, plastic, and other garbage.

Comment: The courts & all coastal states have come out AGAINST off shore drilling as it effects their economy which depends on tourism, beaches, fishing & all other marine activities. Comprehensive studies MUST be done to determine the economic & long term impact drilling would have. Fast tracking should NEVER be allowed when the impact would have such a detrimental effect on so many. NOAA must push back & say NO!!!

Comment: The act of superseding the will of a states residents sets a terrible precedent for future legislation. The people of Florida overwhelmingly voted to restrict offshore drilling. Now the federal government feels that the vote didn’t go there way so they’ll change the rules. State sovereignty should not be treated so frivolously and the wishes of its voters should be honored. Seriously sad that are federal government discounts their wishes to protect their homes.

Comment: I totally oppose any and all lessening of restrictions on off-shore leasing for oil, exploration for oil, etc. It is obvious to anyone who has taken high school chemistry that burning fossil fuels creates CO2, and given the amount of fossil fuels we consume annually — just here in the U.S. we are making a fundamental change in the ppm in our atmosphere which is affecting our weather systems, and is very close to affecting all coastal cities around the planet.

Comment: I am opposed to your streamlining the process of additions or changes to the Coastal Zone Management Plan. These plans have been labored over and worked on by states and communities and were carefully crafted.  For you to have access to just change parts of those Coastal Zone plans is absolutely unthinkable!! PLEASE DO NOT EVEN CONSIDER THIS A WISE WAY TO CONDUCT YOUR BUSINESS!!! California and other coastal states remain opposed to most offshore drilling. They’ve already voted against this practice.

Comment: I’m outraged that this administration thinks that they can expand drilling by slipping in a seemingly innocuous proposal to streamline something called the “federal consistency process” in the Coastal Zone Management Act which affects offshore oil and gas, in the name of efficiency. Rulemaking like this means that this administration has no use for the voices of the states and the citizens of this country.

“Efficiency” in this case means bypassing long-standing environmental laws, rules and studies, and it will have an atrocious impact on the oceans and the environment in general.

Comment: The importance of our coastal ecosystems economically to our coastal states is enormous both through fisheries activities and tourism. To place in jeopardy the health and importance of these resources to our country as a whole for short term profits is foolish, dangerous and lacks insight into the common good for the majority of citizens.

I urge that all efforts are made to block reckless oil drilling in coastal states and to place the protection of our natural resources as a priority by NOAA and other relevant federal agencies.

Comment: There is insufficient reason to speed up the process of review on proposed off shore exploratory drilling for oil. This country needs to move in the direction of developing renewable energy sources that do not add to the problems of climate change but reduce them. The United States, as a disproportionate energy user for many years, should be a leader in the efforts to reduce climate change by conservation and the development of much greater use of hydroelectric power, solar power, and renewable energy sources. 

Streamlining the review process for development of off shore oil drilling moves in the opposite direction and is irresponsible to future generations.

Comment: I am writing to object to the Federal proposal to streamline something called the federal consistency process in the Coastal Zone Management Act affecting offshore oil and gas drilling.  I object to the process that hides government actions that will lead to fossil fuel infrastructure along our east and west coasts. Public objections to oil and gas drilling along these coasts has been consistently strong in each affected state. The “efficiency process” will undermine state’s rights to respond to citizens who voice objection to ocean and beach front contamination from leaks and spills and ugly views of platforms and pipes. Oil companies have a history of spills and failures to clean up and protect the coastal plain ecology.

The proposal allows individual bureaucrats to sneak oil leasing under the radar of public oversight. Proposals like “efficiency process” violates the public trust and violate our coastal health.

Comment: I oppose NOAAs proposed streamlining of the federal consistency process under the Coastal Zone Management Act (CZMA).

This new rule has been proposed “in accordance with Executive Order 13795”, the Trump administration’s nationalist proposal to further energy exploration in coastal waters, and to open up several areas off The U.S. coast to oil and gas exploration, including the sensitive and remote Chuchki and Beaufort Seas and Cook Inlet, as well as along the mid and south Atlantic coast.

It is very apparent from this administration’s choices of people to lead federal agencies having to do with land management and the environment, such as the Interior Department and the EPA, that the president enjoys a close relationship with the oil, coal, and gas industries. Therefore, when this president talks of “streamlining” permitting processes, we have every reason to believe the goal is to rubber stamp new oil and gas exploration, and bulldoze environmental review processes and public comment periods, at the expense of the health of coastal communities, local fisheries, and the climate.

The federal consistency determination under the CZMA has been an important partnership opportunity among coastal states, affected local governments, and federal agencies proposing offshore oil and gas exploration or drilling, and renewable energy projects. States with a federally-approved Coastal Zone Management Plan, acting with and on behalf of their coastal communities, hold a legitimate role in determining whether or not activities associated with federal offshore drilling and other proposed major federal actions are consistent with the states Coastal Plan.

Removal or weakening of CZMA consistency authority — proposed here under the guise of “efficiency” or “streamlining” — would leave coastal states without input or recourse in the face of federal offshore drilling proposals or any decision or plan related to BOEM planning areas (including the seven proposed new ones) on the Outer Continental Shelf, such as an OCS Plan of Exploration, an OCS Plan of Development and Production, or federal permits for adjacent seismic airgun survey programs.

Without the maintenance of a states well-established right to make an effective federal consistency finding, all important decisions, including the subsequent necessary orderly planning to facilitate transportation of any petroleum via tanker, barge, or pipeline, would instead be dictated by federal agencies, rather than continuing to emerge as decisions that are currently co-managed in consultation with affected local governments and coastal states. Considering how negatively all of these oil and gas exploration, drilling, and transport activities could affect coastal communities – including local tourism, recreation, and commercial fishing, this is unreasonable and unjust.

“Comment X”: (Lots of copies of this one!)
(Somebody added a personal starter paragraph…) I live on the shore in Delaware. Off-shore drilling will endanger commercial fishing and tourism, the economic base of the Delaware Bay region. It is too delicate an environment to endanger with lax rules and environmental protections. I oppose this so-called streamlining of the rules.

I am submitting this public comment in opposition to NOAAs proposed streamlining of the federal consistency process under the Coastal Zone Management Act (CZMA).

The federal consistency determination under the CZMA has long provided an essential partnership opportunity among coastal states, affected local governments, and federal agencies proposing offshore oil and gas drilling, seismic airgun petroleum exploration, and renewable energy projects. States with a federally-approved Coastal Zone Management Plan, acting in concert with and on behalf of their coastal communities, hold a legitimate role in determining whether a range of activities associated with federal offshore drilling and other proposed major federal actions are consistent – or inconsistent – with the states Coastal Plan.

I am deeply concerned that the unwarranted removal or weakening of CZMA consistency authority could leave a coastal state virtually defenseless in the face of federal offshore drilling proposals and related decisions leading up to the implementation of an Outer Continental Shelf (OCS) offshore oil and gas lease sale, an OCS Plan of Exploration, an OCS Plan of Development and Production, or federal permits for adjacent seismic airgun survey programs.

Absent the maintenance of a states well-established right to make an effective federal consistency finding, the subsequent necessary orderly planning to facilitate transportation of any petroleum via tanker, barge, or pipeline, would instead be dictated by federal agencies, rather than continuing to emerge as decisions that are currently co-managed in consultation with affected local governments and coastal states. Thus, I oppose this proposed rule.

Background

We already said NO. Some may remember that in 2018, the Trump administration announced plans for new offshore drilling in over 90% of U.S. waters, generating over 1.3 MILLION comments opposing it from private citizens, 330 municipalities, 2,000 elected officials, 45,000 businesses and almost all coastal governors. For what is estimated to be just 2 year’s worth of oil at our current rate of consumption, our government is willing to put ocean tourism and recreation at risk, an industry which creates 12 times more jobs for the US economy than the oil industry.

Sometimes they just explode. It was nine years ago on April 20th (Earth Day!) that the Deepwater Horizon platform drilling BP’s Macondo well exploded. The blast killed 11 rig workers and started the world’s worst oil disaster, with 160 million gallons of crude spewing into the Gulf of Mexico over the course of 87 days. The flow was temporarily capped 3 months later and permanently 2 months after that, but not before threatening the local seafood industry, damaging tourism in four states and leading President Barack Obama’s administration to impose a moratorium on offshore drilling.

They all leak. Even without a dramatic explosion, wells leak. For every 1,000 wells in state and federal waters, there’s an average of 20 uncontrolled releases of oil – or blowouts – every year. A fire erupts offshore every three days, on average, and hundreds of workers are injured annually. The U.S. offshore oil industry had the highest reported rate of fatalities among its international peers, an average of seven times higher than among other U.S. workers

Climate change makes it all worse. During 2004’s Category 4 Hurricane Ivan, one of Taylor Energy’s oil-production platforms was destroyed by a landslide, and has been leaking continuously for the last 15 years, its spill is now close to the level of the BP disaster and with no resolution in sight for the next century. Since Ivan, one of more than 600 storms hat have been tracked in the Gulf since records were kept in the mid-1800s, hurricanes have battered or destroyed more than 150 platforms. Taylor Energy worked hard to keep news of the scale of the leak within Louisiana, a lawsuit was required to get them to reveal any cleanup plans, and the Interior Department spent our tax dollars trying to keep the company from walking away from the disaster. In 2008, Taylor Energy was sold to a joint venture of South Korean companies, and in a 2016 forum, the company president argued that the hurricane’s damage was an act of God. He then asked the government to give them back US$432 million from the $666 million trust set up to clean the spill, after only a third of the leaking wells had been fixed.

The oil industry is the original welfare abuser. The International Monetary Fund study put out a report that the global fossil fuel industry, in direct subsidies, cost underwriting, and environmental damages costs us all $5.3 trillion a year. In a report by OCI, US taxpayers, through tax incentives, credits, low royalty rates, and other government measures benefiting the oil, gas, and coal sectors, annually fund $20 billion of direct fossil fuel production subsidies, $14.5 billion of consumption subsidies, like LIHEAP’s aid to low-income people for heating bills, and $2.1 billion in subsidies for overseas fossil fuel projects (not including this!)

Their key findings:

• Fossil fuel subsidies have been defended by a Congress influenced by $350 million in campaign contributions and lobbying expenditures by the fossil fuel industry – which equates to a 8,200% return on investment.

• The cost of annual federal fossil fuel production subsidies is equivalent to the projected 2018 budget cuts from Trump’s proposals to slash 10 public programs and services that benefit some of the nation’s most vulnerable children and families.
• Government giveaways in the form of permanent tax breaks to the fossil fuel industry – one of which is over a century old – are seven times larger than those to the renewable energy sector.

Meanwhile, the industry has been excused from sweeping upgrades of its aging, leaky equipment. In fact, the Trump administration is working diligently to weaken key safety and environmental protections currently in place. They’re also making it easier for smaller, more financially at-risk companies to participate in off-shore drilling, leaving the taxpaying public to pay $33 billion in platform decomissioning and well capping. These types of companies operate 449 of the 2,104 active facilities in the Gulf of Mexico.

“American” oil doesn’t help America. (Political Climate) “We don’t have nationalized oil companies. In many other countries, oil companies are government-run.  A country taps its own resources and distributes them as the government sees fit.  That, for better or for worse, does not happen here.  “Our” oil companies are huge, privately owned companies that span the globe and act solely in the interest of their stockholders.  It is true that freeing ourselves from our dependence upon unstable, unfriendly countries for their oil would be better for America.  But offshore drilling does almost nothing to accomplish this.”