The Climate in Emergency

A weekly blog on science, news, and ideas related to climate change


1 Comment

BOEM, Again

Remember the BOEM scoping process from a few years ago?

Basically, every five years, the Federal government decides which Federal waters will be available for oil and gas exploration. The process is supervised by the Bureau of Ocean Energy Management, or BOEM, and is somewhat drawn out. In the beginning, all areas that will be considered are included in a proposed map, and public and expert comment is sought. Based on those comments, some areas may be removed from consideration, before the creation of another map and another round of comments. At each stage, the area potentially available to oil and gas extraction can grow smaller, but never bigger. When the final plan comes out, energy companies can lease small areas within those regions made available under the plan, but not every square mile within those regions is ever offered for lease, and not every possible lease is ever exploited. Although BOEM explicitly allows and facilitates oil and gas exploitation, its job is to make sure that such exploitation happens in as safe, as environmentally responsible, and as fair a way as possible.

As possible given the scale of oil and gas exploitation demanded by the economic and political will of the American people.

That last is the key–although BOEM’s job is to say “yes” to people who really should not be said “yes” to, that approval has already been issued by many other entities, including the collective weight of all the American people who buy petroleum products. BOEM’s job is to say a negotiated “yes,” to minimize harm. The BOEM personnel I’ve spoken to have all seemed friendly, helpful, sincere, and genuinely interested in environmental values and fair due process. They depend on us to give them the political cover they need to do the right thing, and they want to help us provide that cover.

BOEM is not our enemy.

Two years ago, parts of the Atlantic were initially considered for exploration, a problem, both because even the safest practices do not reduce the risk of an oil spill to zero, and because the process of locating oil and gas deposits involves sonic testing that is so loud it can kill marine life that happens to be in the way. A lot of us organized and gave public comment, passed local resolutions, and even lobbied Congress. And it worked. Most of the areas originally under consideration, including the entire Atlantic, were removed from the plan. We won! Yay!

And then Present Trump decided to start the whole process over again.

Starting Over

A new presidential administration has the option to re-examine certain decisions of its predecessor, including which areas are available for oil and gas exploitation. Mr. Trump has exercised this option, so we have to go over all of it again.

The obvious motivation for the Trump Administration to re-start the process is a desire to open up more seabed to resource extraction, especially since now, for the first time, almost all American Federal waters are under consideration. But if the process goes as it should, the results should be close to the same as they were last time–most areas should again be excluded.

But even if we win this time, too, there is still a problem, because this process requires quite a lot of work on the part of BOEM personnel–and while they are working on collecting and analyzing comments and making recommendations, they are not doing other things. While discussing the matter with BOEM personnel at a public outreach meeting yesterday, I asked what these other duties are.

Turns out, when not wrangling public comments, many BOEM personnel are involved in conducting environmental impact assessments, identifying gaps in the scientific knowledge used for those assessments, and hiring scientists to fill those gaps. Right now, those duties are still being carried out, but by fewer people. To some extent, this temporary personnel reassignment slows research for some months. More seriously, few people doing the work means fewer minds available to figure out how to solve problems and how to ask research questions.

Do you suppose interfering with research in this way could be the point of this massive do-over?

What to Do?

This is a call to action. Although not directly related to climate change, there are a lot of indirect connection, as I’ve described in previous posts.

The action is fairly simple and user-friendly–make a comment.Obviously this especially addressed to you if you live in the US somewhere coastal, but if you simply care about these areas, please get involved. And remember, we’re talking about almost the entire US coastline and adjacent offshore waters and all the animals and human economic activity (tourism, seafood, etc.) that depend on them.

Feel free to read my earlier posts (like this one) for more information, the issue and the process haven’t changed. There are a number of organizations that have also agreed to provide talking points and links; I’ll update this post when they do so. You can also go to BOEM’s website for more information on the process, a virtual version of the public informational meetings BOEM is holding, as well as how to comment.

BOEM personnel suggest that your comment involve more than “please don’t drill off my beach.” If you have any detailed information on ecological vulnerabilities of specific oceanic areas and coastlines, give those details. If you or someone you know has a strong personal connection to a given area, or if your livelihood depends on the water in some way, say so, and provide details, numbers, data, stories.

Here’s the link to comment again–you have until March 9th.

 

Advertisements


4 Comments

BOEM Scoping, Part 2: Not in My Backyard

Last week, I wrote about how BOEM, a US government agency, is currently accepting public comment about whether to allow oil and gas exploration off the coast of part of the Atlantic Seaboard.

The comment period runs to the end of this month. You can find more information, and you can comment online, here.  You can also comment on the other proposed leasing areas, most of which have already been open for drilling for a while, but if you think that should change, this is your chance to say so.

The reasons some of us don’t want the Atlantic opened for drilling are two-fold.

First, drilling means accidents, sooner or later, and we don’t want anywhere on the Atlantic coast contaminated with oil. I am particularly concerned about the horseshoe crabs. Delaware Bay has some of the most important spawning beaches for horseshoe crabs in the world. Their eggs, in turn, are a critical food source for the red knot, a migratory bird that makes a stop in Delaware to refuel. The red knot population is already crashing, and if the spawning beaches were oiled we could lose the species. Delaware and Maryland have not opted into the drilling program, so our waters are not being considered, but Virginia and North Carolina have. It’s not hard to imagine that a spill off the coast of their states could contaminate our waters.

Second, finding the oil and gas deposits involves blasting the seabed with extremely loud noise. This sonic testing is loud enough to kill or maim wildlife in its path, and to disturb wildlife lucky enough to be farther away. Some of that wildlife–whales, for example–are legally protected, so the oil and gas companies that want to do this testing must apply for a “take permit.” Essentially, they need to ask for permission to kill whales and other animals. Does this really make sense? Is oil and gas really worth the life of whales and dolphins? Do we want mass strandings of disoriented and deafened whales and dolphins dying on our beaches?

I don’t.

Go ahead: comment here.

We went into that meeting hoping to be able to get the Atlantic taken off the table for gas and oil entirely. This comment period is not the last opportunity to ask for that, but it is the most promising. We have the best shot right now that we’ll ever have. I left that meeting much less optimistic. I still say we should go for it; unexpected victories are possible, as long as David actually shows up to the battle with Goliath. But the reasons for my pessimism are important to discuss as well.

What I gathered, from meeting with the representatives of BOEM, was that BOEM is not the enemy (they were all very friendly and helpful) but that they work on the basic assumption that oil and gas exploration will happen. Their job, in their eyes, is to direct the process in such a way as to minimize harm. They may, for example, reduce the area available for lease so as to protect the horseshoe crabs, or to protect whale spawning grounds, as much as possible, and their sister agency, BSEE, will ensure that the drilling itself is done in the safest way possible given current technology. But they will not rule that drilling should not happen at all, even though that is the best way to protect our oceans and coasts, because drilling is a given for them.

As I said last week, I do not think BOEM should be vilified for this order of priorities. I even think it’s possible that the reason the BOEM representatives were so friendly to a group of obvious anti-drilling activists like us is that they want to say “no drilling,” and really hope we can give them the political cover to do that. Realistically, if they oppose the oil and gas industry too vociferously, the industry will likely respond by funding the election of Congressional candidates willing to defund or dismantle BOEM. And if the public does not care about whales and horseshoe crabs and tourism and fishing, those candidates will win. And then sonic testing and drilling will simply happen everywhere. BOEM is not the enemy. Ignorance and complacency are the enemy.

And the assumption that oil and gas exploration will happen is an enemy, an enemy largely created by the American people when they insist upon an economy based on fossil fuels no matter what.

What we’re looking at here is the concept of NIMBY, Not In My Back Yard. The phrase is sometimes used as an insult–someone is a nimby who wants to keep their own neighborhood clean for selfish reasons. I agree with the negative connotation as applied to people who are perfectly happy to mess up other people’s back yards instead. Someone who would rather get their electricity from a coal-fired plant elsewhere than from a wind farm that they have to look at is a nimby in the worst possible sense. But in other contexts, I think the nimbys have it right–certain things shouldn’t happen in anybody’s back yard.

I get in my car, turn the key, and drive to the grocery store, say. Is that trip really worth even a small contribution to sea level rise, species extinction, international conflict?

I tend to think that if anybody really put the matter frankly, this entire fossil fuel project would look like a really bad deal. Hey, let’s destroy whole mountains, pollute rivers, blow up small towns when oil trains explode, gum up birds and fish and poison coastlines when offshore well heads break or oil barges wreck, and warp the atmosphere so that sea level rises and a lot of people have their homes flattened by hurricanes, all so that a small minority of people can get rich and the rest of us can pretend we have a couple of spare planets available.

Sure.

We, in fact, make this deal by how we spend our money and how we vote and we do it because the chance of any of those awful consequences happening to us are very small. Most of the people who benefit from fossil fuels don’t experience injury from them directly. The costs are borne by a small number of people somewhere else. When those people object, they are called nimbys, basically for not being team players. The logic, it seems, is that what benefits a large number of people is worth the loss of life and livelihood of a few, especially if it’s not clear who those few are going to be–we don’t know where or when the next oil spill will happen, only that it will happen somewhere, sometime. Fossil fuel is like a reverse lottery, where everybody buys a ticket and whoever holds the winning number has their property stolen and distributed to everyone else. It looks quite fair from a certain perspective.

Or, we could build a society where one litmus test we apply to any technology or policy is that it not destroy anybody’s backyard.


5 Comments

BOEM Scoping Part 1: Comments Needed

Last week, I attended a protest and an informational event in Annapolis, Maryland. The objective was to keep oil and gas exploration away from our shores.

It is a seldom-discussed fact, but for people who live on the Eastern Seaboard of the United States, large-scale oceanic oil spills are a disaster that happens somewhere else, to someone else. Tragic, and we’re glad to donate money and outrage to the cause, but not really our problem. I don’t mean to sound smug, it’s not like we’re above disaster (we do seem to be developing a problem with hurricanes), it just usually happens elsewhere and we don’t really think about why.

Turns out, the reason we don’t have oceanic oil spills it quite simple; we don’t have off-shore oil and gas exploration, as per US energy policy. And that is about to change. Hence the protest.

The Situation

Where and how energy development takes place in America’s oceans is the purview of the Bureau of Ocean Energy Management, or BOEM. According to one of the handouts I picked up at the meeting,

BOEM promotes energy independence, environmental protection, and economic development through responsible, science-based management of offshore conventional and renewable energy and marine mineral resources. BOEM is responsible for resource management, including leasing, economic analysis, resource evaluation, and environmental analysis.

BOEM is engaging a wide range of stakeholders to gather as much input as possible for consideration of potential new leases in Alaska, the Gulf of Mexico, and the Mid- and South Atlantic.

By “South Atlantic” they mean the sea off the coast of Georgia and South Carolina.

While it may sound odd for a single agency to simultaneously promote both fossil fuel exploitation and environmental protection, it’s worth noting that the alternative–what existed prior to BOEM’s creation–was a piecemeal permit process without any formal means of large-scale planning or public input. As long as fossil fuel exploitation is allowed to exist, there must be agencies capable of limited and shaping the process in accordance with the public and environmental good.

BOEM operates according to the Outer Continental Shelf Lands Act (OCSLA), which states (again, according to the handout) that

The Secretary of the Interior must prepare an oil and gas leasing program every five years showing the size, timing,  and location of potential leasing activity and precisely as possible. The process beings with a Request for Information and culminates with a final program, with drafts and comment periods in between.

The OCSLA process receives input, not just of from the public, but also from an environmental impact assessment, as required by the National Environmental Policy Act (NEPA). In essence, each program defines the areas within which oil and gas leasing can even be considered. The area is divided into small plots and only a small number of those plots are actually made available for lease. Then, before a company actually does anything to the plots it leases, it must do another environmental impact assessment. Oil and gas exploration involves sonic testing, which is harmful to marine life and therefore requires a permit–and the permitting process is again separate from the OCSLA process.  BOEM does not enforce any of the conditions of its various leases and permits, but the Bureau of Safety and Environmental Enforcement, or BSEE, can and does. The BSEE can, if necessary, shut an extraction operation down completely if it violates the law. At least on paper, then, there are a lot of safeguards in place to ensure that the oil and gas industry operates without inflicting undue harm on anybody or anything.

The proposed 2017-2022 Gas and Oil Leasing Program includes parts of the Gulf of Mexico, some of the waters off the coast of Alaska, and areas off the coast of Georgia, South Carolina, North Carolina, and  Virginia. Maryland’s waters are not included, but we’re uncomfortably close to areas that are. BOEM is currently conducting a “scoping process” preparatory to the first environmental impact assessment. That means they are accepting public comment to find out what our concerns are–what we’re worried might happen if drilling in these areas goes ahead. Then, they can address those concerns when they do the assessment. BOEM called the meeting in Annapolis, along with meetings in other affected regions, in order to let the public know how to use the comment process. The comments themselves must be made online or by mail.

We’re hoping that, based on our comments, BOEM will remove the Atlantic from the 2017-2022 program.

The Problem

The problem is that, no matter how safe a drilling operation is, an accident sooner or later is close to inevitable. The Mid- and South-Atlantic sections don’t begin until 50 miles off-shore, which might offer some protection to the coast, but also means that most of the lease areas will be in deep water–just like the Deepwater Horizon, in the Gulf of Mexico. Part of why that disaster was as bad as it was had to do with how far the damaged wellhead was under water. We’re looking at running exactly the same risk in the Atlantic.

Let’s say there is an accident.

We’re looking at a major economic and cultural hit, since a lot of communities in this region depend on the seafood industry, tourism, or both. We’re also looking at a major ecological hit, since both the Delaware and Chesapeake Bays are vulnerable. Just as an example of what’s at stake, the Delaware Bay is a critical stop for the Red Knot on its migration route. The birds “refuel” there by eating horseshoe crab eggs on quiet beaches. Red Knots already have Threatened status under the Endangered Species Act, in part due to the over-harvesting of horseshoe crabs. Now, if those beaches were oiled, as could happen if an oil well in the northern part of the proposed program area leaks badly, what will happen to those horseshoe crabs and those birds?

And even if everything goes perfectly, sonic testing is a routine part of marine oil and gas exploration. This involves blasting EXTREMELY LOUD noises at the sea floor, killing, maiming, or disorienting any marine life that happens to be in the way.

The Event

I went to the scoping meeting with Assateague Coastal Trust, and advocacy organization that stands up for the coastal bays of Maryland, Delaware, and Virginia. Although we knew the meeting would not include any formal opportunity to register our comments, we thought it would do some good for BOEM’s representatives to see and hear us. We arrived early so we and a group from Oceana, another organization, could have a rally out on the sidewalk. There were perhaps thirty of us, waving signs and toy windmills and waving at passing cars. Four people wore fish costumes (two striped bass, one weakfish, and one Atlantic sturgeon) and one wore a hazmat suit. Various reported spoke to us. Cars honked as they drove by. One of the Oceana people said our turn-out was much better than for some of the other scoping meetings that have already happened.

One of the BOEM people came out and told us it was fine for us to rally, but please don’t block the sidewalk or stand in front of the restaurant. We all scooted over cooperatively.

When we went in, the helpful, respectful treatment continued. They asked us to leave our signs behind the front desk, but we were allowed to carry our windmills in and wear our costumes. We got a lot of compliments on the fish. Everyone from BOEM was friendly and welcoming.

There were several information statements and we could wander around and ask questions at each station. We did so, and they answered our questions. They often asked whether their answers were helpful and clear. A few times some of them answered slightly different questions than what we had asked, a common evasive technique, but maybe they were simply trying to be clear when we asked questions that weren’t. Certainly, BOEM representatives frankly admitted to paying a lot of attention to the needs of the energy industry, something they surely would not have done if they were trying to greenwash themselves.

We didn’t see any members of “the public” at the meeting besides ourselves.

The Takeaway

I was heartened by how friendly and helpful the BOEM people seemed. I believe them to be genuine. At the same time, it seemed abundantly clear the BOEM will not say no to the fossil fuel industry as a whole. If the industry wants to extract fuel from the Atlantic, BOAM will use its authority to direct that activity into the least destructive channels possible. It will not say that “least destructive” isn’t good enough.

The truth is that fossil fuel extraction is a given in our society.

But the other truth is that if BOEM hears mostly silence from the public on conservation and a deafening roar from the industry, they will have little choice but to side with industry. They live and work in a political and economic reality that won’t go away by wishing. It’s possible that the BOEM people were so friendly precisely because they welcome the intervention of environmentalists. Many of them are probably environmentalists themselves, fighting a war on the defensive, with very few tools. They need reinforcements badly. We can provide reinforcement by commenting.

They’ll accept comments until the end of the month. Go to http://boemoceaninfo.com/ for information or to comment online.