February 22, 2022

The Honorable Deb Haaland
Secretary of the Interior
Department of the Interior
1849 C Street, NW
Washington, DC 20240

Dear Secretary Haaland,

On behalf of the National Association of Counties (NACo) and the 3,069 county governments we represent, we are writing to urge you to expeditiously hold a Gulf of Mexico (GOM) Outer Continental Shelf (OCS) Region-wide Oil and Gas lease sale by June 30, 2022, per the current 2017-2022 National OCS Oil and Gas Leasing Program. We respectfully request a timeline showing when the next program and sales schedule will be finalized.

NACo recognizes the difficult task the Department of the Interior (DOI) faces while trying to balance its environmental and social stewardship responsibilities, together with its obligations to make offshore waters available for "expeditious and orderly development," obtain a fair return for the nation's resources, and protect the national security interest – all of which historically have been achieved, in part, through twice-annual lease sales on the GOM OCS. As DOI reconsiders its approach to federal oil and gas leasing, counties request DOI also recognize that county interests are furthered by continued federal offshore oil and gas leasing.

Over the past ten years, our counties have received directly over $200 million from federal offshore oil and gas revenue sharing, a significant portion of which has come from just bonuses and rents on new leases. Similarly, many of our counties, particularly those along the gulf coast, relied upon the current leasing schedule when issuing bonds, developing coastal zone restoration and management plans, establishing administrative budgets, and performing other governmental planning responsibilities.

Additionally, counties benefit from the numerous federal, state, and local conservation and recreation initiatives across the United States utilizing the Land and Water Conservation Fund (LWCF), which is funded using revenues from offshore oil and gas (including new lease sales).

However, we are concerned that the administration has not yet held a successful offshore oil and gas lease sale, which means over 36% of all lease sales under the current National OCS Oil and Gas Leasing Program have been canceled or indefinitely delayed.

Amplifying this concern, we are aware that the current program expires on June 30, but considerable work remains for DOI to develop its final program. For instance, DOI historically has published a Proposed Plan and associated Draft Environmental Impact Statement at least six months to one year before the expiration of a current program. Under this timeline, DOI is behind schedule, suggesting that the current federal offshore oil and gas leasing moratorium will last well into 2023.

While we recognize that DOI has continued to approve plans and permits to drill on existing offshore oil and gas leases, this will not be enough to maintain offshore activity, production, and revenues – all of which are critical to counties. For example, there are over 65% fewer leases on the OCS than there were just ten years ago, and oil and gas well production decline rates in the GOM are, on average, around 15% per year. Further, only 40% of GOM exploration wells are commercial wells. New lease sales are necessary to maintain US offshore oil and gas production levels. This production accounts for 15% of the nation's overall production, has among the lowest greenhouse emissions intensity in the world, has associated activity that provides thousands of local direct, indirect, and induced jobs, as well as millions of dollars in local and state taxes.

Counties implore you to end this moratorium by restarting offshore oil and gas leases on federal waters. Without these sales, our counties, local economies, and residents will continue to face detrimental impacts.

Thank you for your time and consideration on this important matter. If your staff have any questions, please don't hesitate to contact NACo Associate Legislative Director Adam Pugh at apugh@naco.org or 202.942.4269.

Sincerely,

Matthew Chase
Executive Director
National Association of Counties