Clinic Submits Comments on the Bureau of Ocean Energy Management’s (BOEM) Draft Second Supplemental Environmental Impact Statement (DSSEIS) for the Chukchi Sea Planning Area
The Emmett Environmental Law & Policy Clinic submitted comments today on the Bureau of Ocean Energy Management’s (BOEM) Draft Second Supplemental Environmental Impact Statement (DSSEIS) for the Chukchi Sea Planning Area. The Clinic’s comments focus on the DSSEIS’s discussion of the risks associated with a very large oil spill and with the potential use of dispersants to respond to such a spill.
The Clinic identifies several flaws in the DSSEIS analysis that must be corrected to effectively address and minimize risk to the Chukchi Sea’s sensitive marine environment. First, the DSSEIS incorrectly assumes that dispersants can be an effective oil-spill response technique when existing research shows that there is considerable uncertainty about their effectiveness. Second, the DSSEIS contains several omissions in its discussion of the potential impacts of dispersant use on wildlife. Lastly, the DSSEIS’ assumption that a very large oil spill can be stopped within 74 days by the drilling of a relief well is unreasonable because it does not take into account the possible winter conditions that could delay the completion of such a well.
Clinic students Rohemir Ramirez Ballagas, LLM ’15 and Alexander Leone, JD ’16, wrote the comments under the supervision of Clinic Director Wendy Jacobs and Senior Clinical Instructor Shaun Goho.