CITY OF PACIFICA
170 Santa Maria Avenue • Pacifica, California 94044-2506 www.cityofpacifica.org
MAYOR
Christine Boles
VICE MAYOR
Greg Wright
COUNCIL
Sue Beckmeyer
Mary Bier
Mayra Espinosa
Scenic Pacifica
Incorporated Nov. 22, 1957
January 12, 2026
Ms. Kelly Hammerle
Bureau of Ocean Energy Management (VAM-LD)
45600 Woodland Rd.
Sterling, VA 20166-9216
Also submitted to https://www.regulations.gov via navigating to BOEM-2025-0483-0001 Re: Comments on 11th National OCS Oil and Gas Leasing Program Docket ID: BOEM2025-0483-0001 MAA104000 pursuant to Federal Register Number 2025-20760.
Dear Ms. Hammerle:
I hereby submit these detailed comments on behalf of the City of Pacifica, California, City Council in response to the proposed lease sale schedule and Draft Proposed Program (DPP) for the 11th National OCS Oil and Gas Leasing Program at Docket ID: BOEM-2025-0015. Further, we object to the scheduling of any of the DPP’s proposed OCS lease sales offshore California and we hereby request a written response from the Secretary of Interior (the Secretary) to each point we raise in these comments.
Further, we also hereby request an extension of the foreshortened public comment period being provided on this inadequate DPP document. The current DPP document fails to comply with Section 18 of the OCS Lands Act and its implementing regulations (30 CFR part 556) due in part as a result of, but not limited to, the obvious lack of a transparent public process being considered at the Department of Interior (DOI), a foreshortened comment period timed to begin immediately prior to two major national holidays during which most public agencies are closed, and the curtailment of public comment opportunities caused by lack of any DOI public hearings in the affected communities. We therefore request an extension of the public comment period beyond the initially advertised deadline and that DOI schedule and conduct a minimum of six duly noticed public hearings to be held in local jurisdictions along the California coast, with two each of such hearings to be held adjacent to all three of the affected OCS Planning Areas.
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 at https://www.federalregister.gov/documents/2025/01/17/2025- 01464/withdrawal-of-certain-areas-of-the-united-states-outer-continental-shelf-from-oil-andnatural-gas 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. We further join with our colleagues in other California coastal jurisdictions in hereby submitting a negative nomination for all tracts in all three OCS Planning Areas offshore California.
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).
Our nearby National Marine Sanctuary (NMS) protections 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 narrowlyauthorized 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 the case of the Monterey Bay National Marine Sanctuary, whose creation was reinforced by the H.R.2027 - Hurricane Andrew Supplemental Appropriations Act for Fiscal Year 1993 during the 103rd Congress (1993-1994), issuing any notice of intent to engage in any pre-lease of OCS leasing activities would require a new Act of Congress.
The DPP Fails to Consider:
1) Which areas of the OCS to lease for oil and gas development by considering the “existing information concerning the geographical, geological, and ecological characteristics” of each OCS region when developing the Five-Year OCS Program. 2) Equitable sharing of developmental benefits and environmental risks among the regions.
3) Existing information concerning the geographical, geological, and ecological characteristics of such regions.
4) The location of affected regions with respect to, and the relative needs of, regional and national energy markets.
5) The location of such regions with respect to other uses of the sea and seabed, including fisheries, navigation, existing or proposed sealanes, potential sites of deepwater ports, and other anticipated uses of the resources and space of the OCS. 6) The interest of potential oil and gas producers in the development of oil and gas resources as indicated by exploration or nomination.
7) Laws, goals, and policies of affected States which have been specifically identified by the Governors of such States as relevant matters for the Secretary's consideration. 8) The relative environmental sensitivity and marine productivity of different areas of the OCS.
9) Relevant environmental and predictive information for different areas of the OCS. 10) Industry’s backlog of undeveloped active OCS leases throughout the Gulf of America, and elsewhere.
BOEM must address California’s existing state waters moratoria rules which preclude new state waters offshore oil and gas leasing and any expansion of existing infrastructure for petroleum activities on adjacent federal leases.
Interior’s current DPP also ignores California’s pre-existing network of 27 local land use ordinances that effectively preclude or complicate any future local permitting of onshore facilities that would be required to deploy equipment or to construct exploratory or development rigs or to process offshore oil and gas along much of the California Coast.
The Federal Register Notice fails to substantiate how BOEM justifies the use of Section 8(k) of the OCS Lands Act (43 U.S.C. 1337(k)) for the described oil and gas leasing activity. The cited Executive Orders and accompanying notices do not legally justify proceeding with the described leasing procedures under the OCS Lands Act (OCSLAA).
Because the primary economic base of our coastal region relies on our thriving visitor-serving industry and commercial and sport fishing activities, the City of Pacifica continues to support permanent protection from any new offshore oil and gas leasing for the entire California Coast.
Thank you for soliciting these comments on behalf of the City of Pacifica, California as duly submitted.
Sincerely,
Christine Boles
Mayor, City of Pacifica
cc: City Council