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Santa Barbara County Comments on the 2002-2007 Draft
Five-Year OCS Leasing Program
January 23, 2001
Mr. Ralph Ainger, 5-Year Program Manager
Minerals Management Service (MS-4400)
Room 2324
381 Elden Street
Herndon, Virginia 20170
RE: Comments on the 5-Year Leasing Program and EIS
Dear Mr. Ainger:
The Board of Supervisors of Santa Barbara County, California submits
the following comments for your consideration. We appreciate the
opportunities that the Minerals Management Service (MMS) provides
for public input on the preparation of 5-year leasing programs.
This Board fully concurs with the MMS' decision to exclude the
Pacific OCS Region from the 2002-2007 leasing program. As stated
in the MMS notice of December 12, 2000, this region is one of several
geographic areas subject to a leasing moratorium by Executive Order
through June 30, 2012. It is also subject to a leasing moratorium
by Congressional action through September 30, 2001, with opportunities
for renewal.
Accordingly, the Board of Supervisors would like to take this opportunity
to identify several reasons that substantiate the wisdom of not
leasing additional tracts in the Pacific OCS Region particularly
offshore Santa Barbara County. Previous impacts to California onshore
producers also causes some concern about the intensity of leasing
offshore Alaska. Lastly, we wish to share some observations about
questions of adequate environmental review that have arisen during
preparation of Environmental Impact Statements for previous leasing
programs. As directed by the MMS notice, these comments are divided
into two separate sections.
Comments on the Preparation of the 2002-2007 Leasing Program
Pacific OCS Region
Five basic reasons illustrate the wisdom of not pursuing any leasing
of new Pacific OCS tracts in the forthcoming 5-year leasing program.
- Historic experience - Previous experience with
leasing oil and gas tracts offshore California was akin to the
great Oklahoma land rush, but produced rather poor results with
regard to the national energy picture.
· 10 lease sales conducted offshore California between
1963 and 1984 yielded a grand total of 371 leases.
· Only 12% of these leases were ever produced to date,
while 79% expired, terminated, or were relinquished by the lessee,
most without ever being explored for oil and gas.
· Those that were developed fed an already glutted, heavy-oil
market in the western U.S.
· With new sources of production from Alaska's North
Slope and the Pacific OCS, many California onshore producers
were forced to shut-in wells and fields for more than 1½
decades and, in some cases, to abandon wells and entire fields
prematurely.
· The undesired result of prematurely replacing California's
onshore production with Pacific OCS production provides a very
important lesson when considering future OCS leasing plans.
- Current status - The considerable delays in developing
OCS leases remaining offshore California illustrates the wisdom
of not pursuing further leasing in the POCS.
· Only 54% of the remaining 79 leases offshore California
have been produced (or are located within producing units).
· That means 46% of the remaining leases offshore California
have yet to be produced. According to current plans and estimates,
only 17% of these undeveloped leases may commence production
by 2007. Another 36% are not expected to produce, if at all,
until after 2015. Given the long delays in developing many existing
leases, the MMS is preparing a programmatic EIS to address environmental
impacts associated with renewing dated Exploration Plans for
15 undeveloped leases. This renewal process runs concurrently
with the preparation of the next five-year leasing program.
· The 79 remaining leases are concentrated mostly offshore
Santa Barbara and Ventura counties. Any consideration of new
leasing would make no sense given this status. These two counties
have had, and continue to have, their hands full with issues
associated with offshore oil development.
- Adequacy of information for making leasing decisions
- The 1989 conclusions of the National Research Council remain
valid: there is inadequate information to make leasing decisions
offshore California. More research remains to be done, peer-reviewed,
and addressed with affected parties before any thought of new
leasing offshore California.
- Preponderance of unresolved issues - Outstanding
issues with current leases, including issues with adequately protecting
coastal and environmental resources, should remain the primary
focus of federal attention in the Pacific OCS. New leasing would
only exacerbate potential resolution of issues such as:
· The disposition of platforms upon termination of leases.
· The improvement of operating procedures to prevent
recurrence of oil spills.
· The assurance that all OCS oil production will be transported
via the safest mode - pipeline - to its final refinery destination
where it is manufactured into final products.
· The consistent application of due diligence to lease
terms.
· The decentralization of decision-making to the state
and local governments via authority granted under the Coastal
Zone Management Act and other statutory measures.
- Impact assistance - A stable stream of federal
funds to local governments remains an elusive promise. Such assistance
is necessary to help local governments plan and prepare policies
in advance to leasing, respond to leasing and other OCS actions
in a meaningful way, and enhance a host of resources adversely
affected by OCS leasing and development.
Alaska OCS Region
We are concerned about potential, unnecessary adverse effects to
California that may result from leasing in the Alaskan OCS Region.
Along with Pacific OCS oil production, the influx of Alaskan crude
oil into the western U.S. market in previous decades resulted in
a substantial and prolonged oversupply of crude oil. This period
of glutted market conditions detrimentally impacted California producers,
including those situated in Santa Barbara County. Several wells
have been shut-in for many years and some wells and fields have
been abandoned much earlier than necessary. Meanwhile, marine tanker
shipments from Alaska to California subjected the California coast
to unnecessary environmental risk from oil spills, due to increased
marine tanker trips from Alaska. Such experience provides a very
important lesson when considering future OCS leasing plans. Such
plans must take particular caution to consider regional market dynamics
so we don't repeat past mistakes of subjecting our coasts to unnecessary
environmental risk, while producing more oil than we need.
Lessons Regarding Previous Environmental Reviews of 5-Year Leasing
Programs
The Board encourages the MMS to substantially improve environmental
review of leasing programs, considering previous experience and
controversy over the adequacy of previous environmental reviews.
- Better define and explain the steps in the leasing and development
process, including lease terms, future environmental reviews,
and situations that could preclude development of a tract or area
identified for leasing in this program. Also clarify the intent
of the program with regard to its relevance to the nation, region,
coastal communities, and marketplace.
- Replace the overly general examination of the past with focused
and thorough analyses of impacts associated with future leasing,
including size and location. This improvement alone would help
to avoid many previous mistakes that led to unrealistic, intensive
lease sales offshore California.
- Conduct more thorough analysis of the risks of oil spills,
including that inherent with human error. Acknowledge the substantially
limited capability of clean up measures and the secondary effects
they beget. Such capability is limited under the best of weather
conditions and is essentially useless under inclement weather.
Also acknowledge the risk of spills from marine tankers.
- Recognize and address the laws, goals, and policies of the
affected coastal states and local communities.
We thank you for the opportunity to comment and look forward to
the MMS' commitment to preclude any new leasing in the Pacific OCS
Region in the forthcoming leasing program.
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Respectfully submitted,
Joni Gray, Chair
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CC: Governor Gray Davis, State of California
Walter Rosenbusch, Director,
MMS
San Luis Obispo County Board
of Supervisors
Ventura County Board of Supervisors
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