Aug 21, 2026 IPAA Comments Regarding NOAA’s Performance Evaluation of the California Coastal Management Program (“CCMP”)
The Independent Petroleum Association of America (“IPAA”) appreciates the opportunity to submit comments regarding NOAA’s performance evaluation of the California Coastal Management Program (“CCMP”) under Section 312 of the Coastal Zone Management Act (“CZMA”), 16 U.S.C. § 1458.
NOAA’s review provides an important opportunity to assess not merely whether California has adopted coastal policies, but whether it is effectively implementing the federally approved CCMP in accordance with the CZMA, including its federal consistency provisions. IPAA recognizes the value of protecting the nation’s coastal resources and supports the balanced approach embodied in the CZMA. Congress established a collaborative federal-state structure intended to reconcile coastal conservation with legitimate national and economic interests.
IPAA’s primary concern in this evaluation is whether California has materially altered the substance of its federally approved coastal-management program through subsequent legislative amendments and administrative implementation without obtaining the approval required by the CZMA. …
