Interiors Authority to Consider Downstream Emissions from Offshore Leasing

The Institute for Policy Integrity asserts that the Bureau of Ocean Energy Management (BOEM) is incorrectly relying on a 2009 D.C. Circuit case, Center for Biological Diversity v. Department of the Interior (CBD), to claim it cannot consider downstream greenhouse gas emissions in its 2023–2028 leasing program. The brief argues that while CBD established that the Outer Continental Shelf Lands Act (OCSLA) does not require such consideration, it does not prohibit it, and that considering these effects aligns with OCSLA's text, legislative history, and regulatory history.

• The Bureau of Ocean Energy Management (BOEM) claims it is unable to consider downstream greenhouse gas emissions for its 2023–2028 Outer Continental Shelf oil and gas leasing program based on the 2009 D.C. Circuit case Center for Biological Diversity v. Department of the Interior (CBD).
• The case Center for Biological Diversity v. Department of the Interior (CBD) only determined that the Outer Continental Shelf Lands Act (OCSLA) does not mandate the consideration of downstream effects, rather than forbidding it.
• There is no case law, including CBD, that prevents BOEM from considering downstream effects, and doing so is consistent with the regulatory history, legislative history, and text of OCSLA.

APA

Sarinsky, L. A. F. D. L. G. A. M. (2022). Interiors Authority to Consider Downstream Emissions from Offshore Leasing. Institute for Policy Integrity. https://policyintegrity.org/publications/detail/interiors-authority-to-consider-downstream-emissions-from-offshore-leasing

Chicago

Sarinsky, Laura A. Figueroa, Donald L.R. Goodson, and Max. Interiors Authority to Consider Downstream Emissions from Offshore Leasing. Institute for Policy Integrity, 2022. https://policyintegrity.org/publications/detail/interiors-authority-to-consider-downstream-emissions-from-offshore-leasing.

Wikipedia

{{cite report |last1=Sarinsky |first1=Laura A. Figueroa, Donald L.R. Goodson, and Max |title=Interiors Authority to Consider Downstream Emissions from Offshore Leasing |publisher=Institute for Policy Integrity |date=6 October 2022 |url=https://policyintegrity.org/publications/detail/interiors-authority-to-consider-downstream-emissions-from-offshore-leasing |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{sarinsky2022interiors, author = {Sarinsky, Laura A. Figueroa, Donald L.R. Goodson, and Max}, title = {{Interiors Authority to Consider Downstream Emissions from Offshore Leasing}}, institution = {Institute for Policy Integrity}, year = {2022}, month = oct, url = {https://policyintegrity.org/publications/detail/interiors-authority-to-consider-downstream-emissions-from-offshore-leasing}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }