Issues » Comments on Rules and Regulations

August 6, 1999

Via mail and facsimile

Ms Ann Bull (MS 5412)
Minerals Management Service
1201 Elmwood Park Boulevard
New Orleans, LA 70123-2394

Dear Ms Bull:

The American Petroleum Institute (API) appreciates this opportunity to submit additional written comments on the scope of the Environmental Impact Statement (EIS) that the Minerals Management Service (MMS) will prepare for the proposed OCS Lease Sale 181 in the Eastern Gulf of Mexico Planning Area. These comments complement the comments filed by API on March 26, 1999, in response to the MMS Call for Interest and Information regarding the proposed Sale 181.

API is joined by the National Ocean Industries Association (NOIA), the Independent Petroleum Association of America (IPAA), the United States Oil and Gas Association (USOGA), the Domestic Petroleum Council (DPC), the Offshore Operators Committee (OOC), and the International Association of Drilling Contractors (IADC). These seven industry trade associations represent many companies engaged daily in all aspects of the oil and natural gas industry. These associations also represent many companies that perform exploration and production activities in federal waters and have a great interest in the proposed sale.

Speaking for the industry, these associations wish to make the following comments:

First, industry reiterates its strong belief that it is in the best interest of the nation, the industry, the Gulf states and the American consumers to conduct Sale 181 in the Eastern Gulf of Mexico in a timely fashion, without deletion of any tracts. As we have stated before, we see no legitimate or logical reason for restrictions on offshore leasing, exploration, and drilling. Only by conducting this sale as scheduled, and without deletions, can MMS fulfill its responsibility under the law to secure the highest return for the American taxpayers from government lands. Only by gaining greater access to offshore exploration can our industry maintain its competitiveness and meet the needs of Americans for a safe, reliable and reasonably priced supply of fuel for their homes, their workplaces and their travel needs.

Secondly, we urge the MMS to resolve the multiple use issues that currently exist between the military and oil and natural gas industry. On July 14, 1999, MMS, Eglin Air Force officials, and industry held a joint briefing to determine the key multiple use issues and to lay the foundation for negotiations to resolve these issues. We believe that joint meeting was a good start. We look forward to further discussions and are hopeful a resolution of these issues will be forthcoming.

Additionally, in preparing its draft EIS, we urge MMS to ensure that any alternatives that include tract deletions from the total number of tracts that now comprise the proposed sale, should be justified by substantive peer-reviewed scientific evidence. Similarly, stipulations that impose restrictions on industry’s ability to explore develop, and produce from tracts should be critically considered against scientific standards. Peer-reviewed science, balanced with the national energy needs and economic considerations, provides the appropriate basis for making sound decisions on tract offerings and lease stipulations.

Finally, we point to industry’s ability to meet environmental challenges – in the Gulf and elsewhere -- in its exploration, development, and drilling activities. This is a record with which you are intimately familiar and about which we are extremely proud, and we urge you to join us in ensuring that it becomes widely known among all interested parties.

Again, we appreciate the opportunity to comment further on Sale 181. If you have any questions, please contact Linda Bauch of API’s Regulatory Affairs Department, 202-682-8170.