Jan 22 Comments on 11th National OCS Oil and Gas Leasing Program - Opposition

January 22^nd, 2026

Ms. Kelly Hammerle
Bureau of Ocean Energy Management (VAM-LD)
45600 Woodland Rd.
Sterling, VA 20166-9216

Re: Comments on 11th National OCS Oil and Gas Leasing Program Docket ID: BOEM-2025-0483-0001 MAA104000 pursuant to Federal Register Number 2025-20760.

Dear Ms. Hammerle, 

On behalf of the Marin County Board of Supervisors, I respectfully submit this comment in strong opposition to the inclusion of any new oil and gas lease sales in the Pacific Region as part of the 11th National Outer Continental Shelf (OCS) Oil and Gas Leasing Program. Our opposition is rooted in longstanding federal, state, and local protections, as well as our County’s deep commitment to safeguarding marine ecosystems, public safety, and coastal economies.

As a matter of public record, on January 6, 2025, a permanent Executive OCS Withdrawal was issued under Section 12(a) of the OCS Lands Act (43 U.S.C. § 1341(a)), withdrawing from disposition all unleased federal waters along the U.S. Atlantic, Pacific, and Florida Gulf Coasts, inclusive of the entire Marin County coastline. Thus, consideration of any tracts within these referenced Executive OCS Withdrawals is outside of the purview of the BOEM, and we urge BOEM to fully exclude the Pacific OCS Region, including the California coast, from further analysis in the 11th National Program.

This is a community priority, as evident by the hundreds of local community members that attended a People’s Hearing here in Sausalito on January 16^th to stand in respectful opposition to the inclusion of the California coast – and all federal waters – in the 11th National Outer Continental Shelf (OCS) Oil and Gas Leasing Program.

As BOEM is aware, all Pacific Coast OCS Planning Areas in the DPP are clearly included in the January 6, 2025, permanent Executive OCS Withdrawal issued under Section 12(a) of the OCS Lands Act (OCSLAA) 43 U.S.C. 1341(a) to protect all unleased federal waters along the U.S. Atlantic, Pacific, and Florida Gulf Coasts, as well as portions of the Northern Bering Sea, from offshore oil and gas leasing for a time period without specific expiration. This includes the entire California coastline. Further, BOEM must also abide by the “Areas Under Restriction” parameters defined here.

Although BOEM claims in its document that their DPP has been published in accordance with Section 18 of the OCS Lands Act and its implementing regulations (30 CFR part 556), the agency’s rushed wholesale area-wide approach to blanket leasing would appear to be legally flawed. Review of the DPP reveals that the document itself fails to comply with a host of longstanding state and federal laws and policies, including but not limited to the National Environmental Policy Act (NEPA), the Endangered Species Act (ESA), the Marine Mammal Protection Act (MMPA), the National Marine Sanctuary Act (NMSA), the Coastal Zone Management Act (CZMA), the National Historic Preservation Act (NHPA), and the Migratory Bird Treaty Act (MBTA). The Interior’s DPP also fails to address the laws, goals, and policies of affected states and local government entities as required under federal law, by ignoring formally-adopted climate mitigation goals, regional policies to conserve energy or to move away from fossil fuels, local land use policies, and the half-century role of localities in the successful creation of their adjoining National Marine Sanctuaries.

Because broad swaths of the federal OCS Leasing Program were already recently arbitrarily deleted from Interior’s drilling consideration under political pressure, as was the case with the Atlantic Coast, the Pacific Northwest, and parts of Florida’s waters, the DPP and the leasing proposal therein would appear to be in violation of the “critical balancing” requirements of the OCS Lands Act as Amended by placing an obviously disproportionate burden of adverse impacts on California’s shoreline communities in comparison to other OCS regions, essentially forcing California’s affected local governments to unwillingly sacrifice their longstanding duly-adopted coastal protection and climate mitigation priorities.

While the DPP informally suggests that only geographic areas smaller than an OCS Planning Area can be identified for exclusion from consideration for offshore oil and gas leasing, our coastal communities are united in our request that the California Coast in its entirety be now removed from the DPP at this step in the process, as was recently undertaken by BOEM for all of the Atlantic Coast , substantial portions of Florida, and the entire coast of our neighboring states of Oregon and Washington. The required balancing of environmental risks and economic benefits among the OCS regions clearly stipulates equivalent consideration of similar protective treatment for the California Coast according to OCSLAA. 

A state such as California, with a federally approved Coastal Zone Management Program (CZMP), will eventually likely be compelled to exercise its duly held authority over any federal action that directly affects the land and water uses of the affected state. If and when Interior’s proposed offshore OCS leasing process goes forward, the State of California and its coastal local governments will inevitably be appropriately raising this issue of Federal Consistency in order to protect their intrinsic rights under the Coastal Zone Management Act (CZMA).

Marin County, along with all counties in California, have a duly enacted Local Coastal Plan (LCP), which is a subset of the California Coastal Plan (CCP), formulated under the auspices of the federal Coastal Zone Management Act (CZMA). Our priorities for managing our jurisdictional authority along the California coast reflect ecosystem and fisheries sustainability, public access, and maintenance of a growing Clean Coast economy. We request that these protocols be respected and that Interior forgo leasing for oil and gas off of the California coast in order to preserve these values.

Marin County has long supported the permanent protection of our coast from offshore oil and gas development. This position is reflected in our Board-adopted Legislative Platform, which explicitly opposes new leasing activity in offshore federal waters and supports the continued protection of National Marine Sanctuaries. Notably, the Cordell Bank and Greater Farallones National Marine Sanctuaries—both directly offshore from Marin—are among the most ecologically rich and sensitive ocean areas on the West Coast.

Marine Sanctuary Protections

Portions of the Marin Coast include National Marine Sanctuary (NMS) protections that play a central role in this region’s economic well-being, the health of our surrounding ecosystems, the quality of life and recreational opportunities enjoyed by our citizens, and our community’s ability to plan for a sustainable future. Our jurisdiction played a constructive role in obtaining the designation of our National Marine Sanctuaries, and the timing of the designation of each Sanctuary or portion thereof plays no role in whether or not BOEM can consider its waters are permanently protected from OCS leasing and related activities. All of our Sanctuary waters are permanently protected from offshore oil and gas leasing and all related activities.

Every National Marine Sanctuary has a Designation Document, a Management Plan, and Site Regulations, and for those Sanctuaries offshore California, each of these documents contains a strict prohibition on offshore oil and gas leasing and related activities, as stipulated in various ways in each of those documents. The overarching regulatory framework, among other protocols, lists as prohibited or otherwise regulated activities, essentially the following: 

1. Exploring for, developing, or producing hydrocarbons within the Sanctuary, 

(2) Exploring for, developing, or producing minerals within the Sanctuary, 

(3) Discharging or depositing from within or into the Sanctuary any material or other matter, except as narrowly identified, 

(4) Discharging or depositing from beyond the boundary of the Sanctuary any material or other matter that subsequently enters the Sanctuary and injures a Sanctuary resource or quality, except as specifically identified, and 

(5) Drilling into, dredging, or otherwise altering the submerged lands of the Sanctuary, or constructing or placing any structure, material, or other matter on or in the submerged lands of the Sanctuary, except as incidental and necessary for certain narrowly authorized purposes. Further regulations within California’s National Marine Sanctuaries also preclude taking or possession of certain marine mammals and birds, defacing signage, release of an introduced species with certain exceptions, and additional prohibited or otherwise regulated activities within marine reserves and marine conservation areas. It should be noted that any federal effort to lease OCS tracts inside of a National Marine Sanctuary is precluded, or to in any way attempt to modify any of the applicable governing documents mentioned above, would of necessity trigger a transparent public process involving extensive comment opportunities and requiring related public hearings.

In addition to these sanctuaries, Marin’s coastline is home to several overlapping layers of conservation status and ecological importance, including:

• The Farallon Islands, which host the largest breeding colony of seabirds in the continental United States and support vital marine mammal populations.
• Longstanding federal protections, including the Point Reyes OCS Exclusion Zone (1978), the original Gulf of the Farallones National Marine Sanctuary (1981), and subsequent expansions including the Monterey Bay and Greater Farallones sanctuaries.
• State-level protections, including Marine Protected Areas (MPAs) designated under California’s Marine Life Protection Act (MLPA), and
• Inclusion within the Golden Gate UNESCO International Biosphere Network, which encompasses both terrestrial and marine areas along Marin’s coast and within the 200-mile U.S. Exclusive Economic Zone.

These layered protections reflect decades of bipartisan federal and state efforts to preserve one of the nation’s most ecologically and economically valuable marine environments. New leasing and associated activities—including seismic surveys, seabed disturbance, and the risk of oil spills—are incompatible with the conservation mandates and statutory protections governing these areas.

Moreover, our local coastal economy depends on clean water, sustainable fisheries, tourism, and outdoor recreation. These sectors are central to local jobs and households. Offshore oil and gas development poses unacceptable risks to our economy, as well as to the public health and environmental integrity of communities.

In closing, we again urge BOEM to fully exclude the Pacific Region, including California’s coastal waters, from any lease sale consideration in the 11th National OCS Oil and Gas Leasing Program. This position reflects both the legal constraints under current Executive withdrawal authority and the longstanding scientific, environmental, and economic rationale for safeguarding this region.

Sincerely,

Eric Lucan
President of the Board of Supervisors

CC:       Marin County Board of Supervisors
Congressman Jared Huffman
Senator Alex Padilla
Senator Adam Schiff