This is a public comment letter in which the Pew Environment Group's U.S. Arctic Program comments on Shell Offshore Inc.’s (Shell’s), Revised Outer Continental Shelf (OCS) Lease Exploration Plan (EP), and Revised Chukchi Sea, Regional Exploration Oil Discharge Prevention and Contingency Plan (ODPCP). This letter provides an extensive list of recommendations for the Bureau of Ocean Energy Management (BOEM) and Bureau of Safety and Environmental Enforcement (BSEE) to consider in making its decision.
Sample text from the letter:
“The drilling risk in the Chukchi Sea is higher than in the Beaufort Sea because fewer wells have been drilled historically. Of the 65 exploration wells drilled in the U.S. Arctic Ocean, only five of those were drilled in the Chukchi Sea over 20 years ago (from 1989 to 1991). Additionally, BOEM’s Very Large Discharge (VLD) blowout analysis shows that exploration drilling in the Chukchi Sea would result in a substantially higher potential well blowout 61,000 barrels of oil per day (bopd), versus 25,000 bopd in the Beaufort Sea.”
