On July 12th, U.S. Secretary of the Interior Ken Salazar issued a “Decision memorandum regarding the suspension of certain offshore permitting and drilling activities on the Outer Continental Shelf.”
His memorandum is 22 pages long, with an additional 7 pages of supplementary information.
Sec. Salazar’s language is clear and direct, and he begins by pointing out that he has a responsibility to act when a threat is observed, and he presently sees “a clear threat” (p. 2). His duty in this regard is not constrained by any requirement to balance the harm which may occur by the Secretary’s actions to mitigate a threat. But Salazar points outs, “Even if I had to engage in a balancing of the economic effects… I would conclude that a temporary suspension of drilling operations is warranted…. [T]he economic impact of a suspension… is outweighed by [the] economic impact of another catastrophic event” (p. 16).
Salazar cites several reasons for choosing Nov. 30 as the end-date for the moratorium which I will not repeat here (see pgs. 20-21). But the single over-riding determiner of both the end-date and the need for the suspension itself may be summed up in one word: uncertainty.
The Secretary points out that “… deepwater drilling is a relatively young and still-evolving enterprise (having only begun in earnest in the late 1990s)…” (p. 3). He also points out that given the commonalities across the offshore industry, “… we simply don’t know if the BP situation is unique” (p. 4). In this regard he might have added an additional reason: the lax procedures of the Minerals Management Service leave everyone wondering how many short-cuts have been allowed to slip through over the years.
Meanwhile, Salazar is quite certain about many things:
In short, Sec. Salazar’s memorandum is a highly readable and well-reasoned document, and well worth the time required to consider it in its entirety:
Secretary Salazar’s July 12th Decision Memorandum
Salazar’s concerns are applicable not only to deepwater drilling in the U.S. Outer Continental Shelf, but to deep-water drilling world-wide. On July 7th the energy commissioner for the European Union said that the EU should consider a moratorium on “frontier operations” where there are “extreme parameters and conditions: ”Energy Commissioner Oettinger called for the same prudent approach which has been requested by Salazar, saying, “Given the current circumstances, any responsible government would at present practically freeze new permits…..”