Page 24 - IAGC The Voice 2017

The IAGC's comments on the Draft Endangered Species
Act (ESA) Compensatory Mitigation Policy state the
U.S. FISH AND WILDLIFE policy would result in adverse policy outcomes. The
SERVICE DRAFT comments also assert the policy is the U.S. Fish and
Wildlife Service's attempt to exercise authority beyond
ENDANGERED SPECIES what Congress has conferred through the ESA or any
ACT COMPENSATORY other statute and falls significantly short of stated
goals. Under the Draft Policy, compensatory mitigation
MITIGATION POLICY will be required in contexts it has never been used, at
unprecedented scales, and on impracticable deadlines
for species over which the 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
clear how the draft Plan will improve the current
processes. The draft Plan does not help to clarify DRAFT MID-ATLANTIC
understanding of how improvements in interagency
coordination will be achieved. Comments suggest that REGIONAL OCEAN ACTION
interagency coordination goals could be achieved PLAN
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, and Alaska Oil and Gas
Association (AOGA) Final Environmental Impact Statement
FINAL EIS FOR EFFECTS OF (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 Ocean Bottom Cable
(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• the outdated and incorrect FEIS's Effects Analysis, which is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, API, and AOGA also submitted extensive comments
on the 2011 Draft EIS and the 2013 Supplemental Draft EIS
that preceded the FEIS.
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