API, IAGC, and our respective members are committed to environmental protection and ensuring that G&G exploration is carried out in a responsible manner. Industry’s long-standing and ongoing research into these issues reflects those interests. We do not, however, support ineffective, unproductive, or unreasonable requirements, and we have concerns that the contemplated LTMP would include these types of requirement.
We are genuinely disappointed that what was a constructive process involving meaningful public input has been supplanted with the abrupt issuance of arbitrary conclusions resulting from NOAA’s election to prioritize speedy, unilateral, and rash decision-making above transparency, diligence, and adherence to best science. As set forth above, we cannot support the adoption of the 2016 proposed changes, particularly when the changes modify criteria that were already peer reviewed and subject to a reasonable public review and comment period.
For the energy industry, modern seismic Imaging reduces risk, increasing the probability that exploratory wells be drilled successfully and are hydrocarbon; and decrease the number of wells that need to be drilled in a given area, reducing the associated risks of safety environmental impacts and global footprint of exploration. The above due to seismic exploration activities are temporary and transitory; It is therefore the means less intrusive and more cost-effective for obtaining resources from the subsoil that currently exists in the world.
The Draft Compensatory Mitigation Policy exceeds the Service’s statutory authority and relies instead on authority FWS seeks to confer to itself. The Draft Policy undermines the objectives it purports to advance because, in reality, it has been designed to pursue objectives that are completely distinct from conservation.
IAGC supports adoption of streamlined OHS regulations for offshore oil and gas exploration and development in Canada. We understand the current consultation process represents phase 1 of the initiative to develop regulations for replacing the transitional regulations set to expire in December 2019.
While our industry does not currently engage in offshore exploration or development in the Mid-Atlantic Outer Continental Shelf (“OCS”) of the U.S. Exclusive Economic Zone, seismic surveys and drilling in the Mid-Atlantic have occurred in the past, enhancing understanding of the resource potential in this region.
The Associations support modernizing and streamlining the regulations for onshore and offshore oil and gas exploration and development in Canada. We understand that the Boards will continue to be responsible for the management and implementation of regulation of oil and gas activities. However, individual Boards’ interpretation of regulations may not align with the policy intent of FORRI, especially where the initiative’s intent is not specific, but ambiguous.
The Associations’ members have significant interest in ensuring that future opportunities for offshore oil and natural gas exploration and development in the Gulf of Mexico (“GOM”) are not unduly restricted by expanding the FGBNMS to include new geographic areas for which expansion is not appropriate or with boundaries in excess of those needed to protect appropriate areas.
The Associations commend NOAA for the long-term planning, transparency and agency coordination principles underlying development and publication of the ONS Roadmap. The Associations further commend and strongly support advancement of science-based coordinated programs such as envisioned in the ONS Roadmap.
We find it would be premature to apply the acoustic thresholds in forthcoming regulations and authorizations and urge NMFS to undertake additional review and revision of the Guidance that includes additional input from relevant user groups/stakeholders.
While publication of the Final Approved Environment Plan for an Offshore Activity may be of value, IAGC is of the opinion that publication of a Full Draft Environmental Plan as part of the consultation process would significantly extend project approval lead-times with no environmental benefit.
The Associations have been fully engaged in this process and have spent substantial amounts of time and resources evaluating both versions of the Draft Guidance and preparing comments to constructively inform this important process. Our position has been, and continues to be, that we will support a process that is comprehensive, transparent, consistent with the best available science, and fully informed by the public.
IAGC, among many trade groups submitted comments in response to the Bureau of Ocean Energy Management’s Draft Programmatic Environmental Impact Statement (DPEIS). Our comments generally support Alternative A as the Preferred Alternative provided no additional areas are removed for consideration from future leasing. We strongly encourage BOEM to reconsider the range of alternatives analyzed and the rationale for eliminating certain alternatives from full analysis under NEPA and specifically recommend that a less restrictive alternative be analyzed and that reconsiders the decision regarding potential Atlantic leasing.
21 April, 2016 IAGC Comments on Administrative Provisions of a General Nature on the Social Impact Assessment in the Energy Sector
IAGC submitted a second set of comments to CNH in Mexico regarding the draft Administrative Provisions on the Social Impact Assessment in the Energy Sector. The draft provisions pertain generally to the energy sector but also have potential impacts on G&G activities. IAGC’s comments, in general, suggest that any activity should be exempted from presenting the Social Management Plan if the Social Impact Assessment proves that the project will have no direct interaction with human settlements or have low social significance, and therefore no need to present social prevention and mitigation measures.
IAGC submitted comments on April 4th to the Northern Territory Government in Australia responding to draft environmental regulations for the petroleum industry. Our comments focus on the draft’s definition of ‘stakeholder’ among reiterating the temporary and transitory nature of seismic operations. Specifically, we commented that the definition of ‘stakeholder’ was too broad and should be narrowed to include only those with material interests in the specific regulated activity.
4 December, 2015 IAGC Comments on regulations in Columbia