Stop seafloor mining off Virginia's coast

What the public could have raised, from the agency’s own document

• I oppose this action as proposed, and I ask the agency to weigh the specific harms below.
• BOEM states it will focus environmental review on preliminary activities only, but then acknowledges that subsequent operations will require additional environmental review later. This contradicts the statement that this RFI and environmental process will support the lease sale decision, since major operational impacts—exploration, development, and production—are explicitly deferred for later review. Section 2 should clarify whether the current NEPA review is adequate for the lease issuance decision or whether BOEM is improperly segmenting environmental review.
• BOEM requests comments on potential royalty rates, rental rates, minimum bids, and lease term duration, suggesting these financial terms are not yet determined. However, BOEM has already decided unilaterally that royalties will be applied to 'all marketable mineral production.' BOEM should clarify what discretion remains over royalty policy and justify why this key term was predetermined rather than left open for public input.
• BOEM requests information on whether 'adjustment or suspension of rental payments' should be allowed under certain conditions, but the RFI provides no baseline rental rate for commenters to evaluate or negotiate. Without a proposed rental rate in writing, public comments will be uninformed and BOEM's evaluation of responses will lack a rational framework. BOEM should publish a preliminary rental rate proposal.
• BOEM invites comments specifically on 'barriers to leasing and production' and asks commenters to identify regulatory obstacles they believe BOEM 'should be aware of,' which invites responses seeking agency deregulation. This framing presupposes that regulatory barriers are obstacles to remove rather than environmental or safety protections to maintain. BOEM should neutrally request input on applicable legal requirements without suggesting that barriers warrant elimination.