Offshore Oil and Gas Leasing

The Georgia Conservancy's August 2017 Comments to the Federal Bureau of Offshore Energy Management (BOEM) Regarding the 2024 National Outer Continental Shelf Oil and Gas Leasing Program

The Georgia Conservancy appreciates this opportunity to submit information and comment on the Oil and Gas Leasing Program for the Outer Continental Shelf (OCS) in the Atlantic Ocean off Georgia’s coast. As noted in the Federal Register announcement for this program (82 Fed. Register 126, July 2, 2017), the last such lease program that affected the Georgia Coast was in 1983. The Georgia Conservancy had a major role in opposing leasing for offshore drilling then, and we have an even heightened level of concern now, 34 years later.

Our issues with the oil and gas leases center primarily on the numerous ways it would damage critical ecosystems and disrupt the lives and economy of our coastal residents. There are more than 40 years of sound science that need to be considered in this round of Bureau of Ocean Energy Management (BOEM) assessments. It is critical that the federal review process not be hurried for the sake of an energy independence policy wrought by a change in Administration. 

The Georgia Conservancy is a statewide conservation organization that works to develop solutions to protect Georgia’s environment through advocacy and collaboration on water, air, land and marine conservation issues. Founded in 1967, we are one of Georgia’s oldest conservation-based nonprofit organizations and have a long history of advocating for coastal protection. We have had a coastal office in Savannah since 1972.

Our Coastal Policy states that the Georgia Conservancy envisions a healthy resilient and diverse coastal ecosystem that can endure natural and human disturbances, continue to perform its functions, and support self-sustaining populations of native fish, birds, wildlife and plants.

The comments and questions in this letter should be considered specific to the Georgia Coast, which is part of the South Atlantic Planning Area.  The Georgia Conservancy stands with other environmental organizations to call into question if South Atlantic Area leases are even justified and to question the hurried manner being used to reconsider the OCS Oil and Gas Leasing program when a previous administration excluded this area less than two years ago. 

Former Interior Secretary Jewell announced on November 11, 2016 that the 2017-2022 OCS leasing plan would not include the Atlantic, in large part because BOEM data from the 2016 finding showed that more than 70 percent of the recoverable oil was included in the already-approved lease program. 

North Atlantic right whale and calf (GA DNR)

North Atlantic right whale and calf (GA DNR)

We specifically request that Section 18 of the OCS Lands Act provide a detailed analysis of oil well disaster scenarios and the cumulative impacts related to spills and long term effects on Georgia’s salt marshes.  Georgia’s extensive estuaries comprise one third of the East Coast’s remaining salt marshes, and they play a critical role in maintaining our shrimp and fish populations.  Further compounding the issue, Georgia’s coast is home to various endangered marine species. These include the North Atlantic right whale (NARW), one of the most endangered whales in the world, with only about 500 remaining.  The Georgia Conservancy has a long history of advocating for the protection of the NARW, Georgia’s official marine mammal.

In 1975, the Georgia Conservancy became an active stakeholder when we started to follow plans to develop domestic oil production on Georgia’s coast. In May 1976, the Georgia Conservancy began working with what would become the Coastal Zone Management program, created to bring together government, petroleum industry, and environmental representatives to consider the onshore impact of offshore oil and gas development.  Then as now, the Georgia Conservancy realizes such oil drilling off our coast would bring demands on public services, oil spills and health hazards, as well as jobs and economic profit.  If these leases are approved, there will be a major question looming for our coastal communities as they struggle to deal with our disrupted tourism and seafood industries.

Since the 1970s, a host of partner organizations working collaboratively has greatly advanced our understanding of the unique coastal ecology of Georgia’s offshore, marshes and critical nearshore habitats. These organizations have included the Georgia Department of Natural Resources’ Coastal Resource Division, the University of Georgia Skidaway Institute, The Georgia Conservancy, The Nature Conservancy, Grays Reef National Marine Sanctuary and Sapelo Island National Estuarine Research Reserve. During this time, the population of Georgia’s coastal region has more than doubled.  Given the unique conditions of Georgia’s coast with only four of the 14 barrier islands being inhabited, any offshore oil and gas piping or support infrastructure will be located in populated areas (barrier island or mainland) or in conserved critical maritime coastal habitat. 

We ask that the next step of this BOEM Oil and Gas Leasing Program, the development of the Draft Proposed Program (DPP), include a detailed consideration and balanced assessment of ecological, hazardous and economic impacts based on a compilation of comprehensive data sets which address Georgia-specific features of our nearshore and coastal environments.  Our federal agencies and elected officials need to recognize that the Georgia has done a remarkable job protecting our coastal assets for the benefit of our citizens, and that the largest functioning marsh estuary on the East Coast should not be jeopardized by this leasing program. 

In closing, the Georgia Conservancy does not believe that allowing oil and gas drilling in Georgia’s offshore waters is in the best interests of our state or nation. The risks far outweigh the reward. We appreciate the opportunity to voice our concerns in hopes that you will use science and economic data to show that it does not make sense to lease areas off the Georgia coast for oil and natural gas drilling.

Click here for more information on the Georgia Conservancy's Coastal Program