June 11 Comments on the Federal 11th National OCS Oil and Gas Leasing Program

June 11, 2025

Ms. Kelly Hammerle
Program Manager
Bureau of Ocean Energy Management (VAM–LD)
45600 Woodland Road
Sterling, VA 20166–9216

RE: Comments on the RFI for the 11th National OCS Oil and Gas Leasing Program identified as Docket ID: BOEM-2025-0015

Dear Ms. Hammerle:

Thank you for the opportunity to provide comments on behalf of the County of Marin in response to the Bureau of Ocean Energy Management’s (BOEM) “Request for Information” regarding the preparation of the 11th National Outer Continental Shelf (OCS) Oil and Gas Leasing Program (Docket No. BOEM–2025–0015).

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.

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.

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.

California law prohibits new leasing in state waters, and state agencies have consistently objected to any expansion of offshore oil and gas leasing in adjacent federal waters. As required by Section 18(a)(2)(F) of the OCS Lands Act, BOEM must give due consideration to the laws and policies of affected states and ensure consistency with the Coastal Zone Management Act.

As a County, we are also advancing practical efforts to reduce long-term dependence on oil and gas through local clean energy programs, electrification, and coastal resilience planning. New offshore oil and gas leasing in the Pacific would undermine this progress and extend investment in infrastructure that no longer reflects regional priorities.

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,

Mary Sackett, President
Marin County Board of Supervisors

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