On March 20, 2013, the Clinic submitted comments to the Bureau of Safety and Environmental Enforcement (BSEE) on BSEE’s Draft Safety Culture Policy Statement for Offshore Drilling. In the comments, the Clinic argues that the draft’s focus on process safety is overly narrow, and that the Bureau should “guide organizations…
On December 22, 2014, the Clinic submitted comments on the Bureau of Ocean Energy Management’s (BOEM) Draft Second Supplemental Environmental Impact Statement (DSSEIS) for the Chukchi Sea Planning Area, OCS Oil and Gas Lease Sale 193. The Clinic’s comments focused on BOEM’s analysis of the impacts of a Very Large…
On May 27, 2015, the Clinic submitted comments on the Department of the Interior’s (“DOI”) proposed regulations for offshore exploratory oil drilling in the Arctic. The Clinic supported the agency’s proposals to require that operators maintain a secondary drill rig in the Arctic to respond to potential losses of well…
This white paper, published in June 2012, is the first step in a multi-semester project of the Clinic to make recommendations for the effective regulation of offshore drilling in the Arctic. Based on a review of 40 domestic and international regulatory programs in the areas of health, safety, environment, and…
This December 2013 report suggests a set of performance indicators for use to evaluate and predict the environmental performance of companies proposing to drill for oil or gas in the U.S. Arctic. In developing this suggested set of indicators, the Clinic attempted to address all aspects of offshore oil and…
This December 2014 report recommends mechanisms for facilitating public access to, and intra- and inter-agency sharing of, information from companies engaged in offshore drilling. The Clinic focused specifically on the accessibility of information collected by the Department of the Interior’s Bureau of Safety and Environmental Enforcement (“BSEE”) because of BSEE’s…
On March 13, 2019, the Clinic submitted comments to the Bureau of Land Management (BLM) regarding the Draft Environmental Impact Statement (DEIS) issued by BLM to implement an oil and gas leasing program within the Arctic National Wildlife Refuge Coastal Plain. The Clinic encouraged BLM to revise the DEIS’ analysis…
