Page 24 - The Voice 2017

The IAGC's comments on the Draft Endangered Species
Act (ESA) Compensatory Mitigation Policy state the
US FISH AND WILDLIFE policy would result in adverse policy outcomes. The
SERVICE DRAFT comments also assert the policy is the Service's attempt
to exercise authority beyond what Congress has conferred
ENDANGERED SPECIES through the ESA or any other statute and falls significantly
ACT COMPENSATORY short of stated goals. Under the Draft Policy, compensatory
mitigation will be required in contexts it has never been
MITIGATION POLICY used, at unprecedented scales, and on impracticable
deadlines for species over which Fish and Wildlife
Service has no jurisdiction.

Comments to the BOEM note that while the draft Mid-
Atlantic Regional Ocean Action Plan largely focuses on
common sense actions, like getting agencies to collect
more data, consult effectively, and make information
more available to interested stakeholders, it is still not DRAFT MID-ATLANTIC
clear how the draft Plan will improve the current
processes. The draft Plan does not help to clarify REGIONAL OCEAN ACTION
understanding of how improvements in interagency
coordination will be achieved. Comments suggest that PLAN
interagency coordination goals could be achieved
through other means outside the Regional Planning
Body (RPB) processes which do not require new
bureaucracies like the RPB or directives established in
vague terms in the Plan.

The 21 November 2016 IAGC, API, AOGA Final
FINAL EIS FOR EFFECTS OF Environmental Impact Statement (FEIS) comments highlight:
OIL AND GAS ACTIVITIES • the lack of demonstrated need for an EIS for Arctic oil and
gas exploration activities;
IN THE ARCTIC • the unreasonableness of the content and scope of the
Alternatives;
• the incorrectly defined activities addressed in the
alternatives;
• the FEIS's use of the term "program," which still creates
potential for confusion and complication;
• the incorrectly-stated no-action alternative;
• the need to revise the description of OBC surveys;
• the outdated and incorrect FEIS's Effects Analysis, which is
not based on the best available science; and
• the arbitrary and erroneous key impact findings in the
FEIS.

The IAGC, AOGA, and API also submitted extensive comments
on the 2011 Draft EIS and the 2013 Supplemental Draft EIS
that preceded the FEIS.

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