In April 2025, the Trump administration’s Bureau of Ocean Energy Management (BOEM) initiated the preparation of the 11th National Five-Year Oil and Gas Leasing Program in the Outer Continental Shelf (OCS), following Trump administration orders on “Unleashing American Energy.” The National OCS Program provides a schedule of public oil and gas lease sales in the OCS—the legally-defined areas of submerged land off the coast of the United States that do not fall under the jurisdiction of individual states. The 11th OCS Program would replace the current 10th OCS Program (2024–2029), which scheduled the fewest oil and gas lease sales in US history. The development of a new National OCS Program begins with a request for information (RFI) comment period, which fossil fuel entities have historically used to push their agenda. InfluenceMap analysis of the responses to the comment period reveals how the US oil and gas sector continues to leverage pro-fossil fuel narratives around energy security and affordability to justify expanded offshore production.
In June 2025, three oil and gas companies (BP, Chevron, and Shell) and 12 major industry associations tracked by the LobbyMap database submitted comments that strongly supported the initiation of a new leasing schedule and advocated for new offshore fossil fuel production in the OCS. In their responses, entities deployed narratives that frame offshore fossil fuel production as critical to maintaining a robust economy and secure energy supplies, playing on recurring themes of job creation, federal and state revenues, and national security. This framing is deceptive: the Intergovernmental Panel on Climate Change (IPCC) emphasizes that renewables can now compete without financial support and are often cheaper than fossil fuels in various regions, and identifies the development of renewable energy as a crucial measure for enhancing energy access and security. IPCC reports also emphasize that continued fossil fuel development is incompatible with limiting global warming to 1.5°C. InfluenceMap’s Fossil Fuel Misinformation Tracker outlines in detail how actors around the globe have coordinated this playbook of narratives to oppose and delay the energy transition. The graphic below illustrates the appearance of these narratives in each of the regulatory comments.
In their advocacy, industry actors used these misleading narratives to push for more frequent lease sales and additional acreage to be made available for development, naming specific regions for increased or new development including in the Atlantic, Alaska, Gulf of Mexico, and Pacific regions:
BP and Shell positioned the OCS as a vital component of the US energy portfolio, while Chevron stated that “offshore production helps fuel the economic engine that drives our economy and supports a quality of life that is unparalleled among the developed countries of the world.” Shell specifically emphasized concerns that coastal states could block development off their shores and called to limit state authority to veto projects.
A joint letter by the American Petroleum Institute (API), Independent Petroleum Association of America (IPAA), and American Exploration and Production Council (AXPC) urged BOEM to expand access to previously off-limits unexplored OCS areas “to strengthen domestic energy production, support high-quality jobs, and drive broader economic benefits across coastal and inland communities.”
The US Chamber of Commerce stated that “a robust National Program plays an important role in our energy security, which in turn plays a key role in America’s economic success” and called for increased fossil fuel production to meet rising energy demands from artificial intelligence and data centers. Consumer Energy Alliance (CEA) signed onto this comment and reiterated these points in a separate comment.
A coalition of major industry groups, "Allied Trade Associations Supporting Offshore," highlighted OCS development as a “critical economic driver,” called for the inclusion of “all Outer Continental Shelf (OCS) planning areas,” and emphasized the importance of oil and fossil gas producers to the US economy. Signatories included the American Chemistry Council, AXPC, API, CEA, Illinois Chamber of Commerce, IPAA, LNG Allies, National Association of Manufacturers, National Propane Gas Association, Texas Oil & Gas Association, and Western States Petroleum Association.
BOEM will analyze public submissions to the RFI before it publishes a Draft Proposed Program, which will undergo two further rounds of public comment before final approval. This process likely serves to legitimize the Trump administration’s desired policy outcome. In January 2025, Trump revoked a Biden administration decision that authorized the largest-ever withdrawal of OCS lands from future oil and gas leasing, resuming and accelerating federal offshore fossil fuel development efforts. The Trump administration has further signaled its intent to support the oil and gas industry through both its deregulatory agenda and key cabinet appointments, including the appointment of former oil lobbyist Matt Giacona as acting director of BOEM. With fossil fuel interests steering public comments and holding key positions within the agency, the 11th OCS Program is likely to expand oil and gas leasing and lock in higher-emission energy sources into the next decade.
The Intergovernmental Platform on Biodiversity and Ecosystem Services (IPBES) Nexus Report (Dec 2024) makes clear that human activity is driving biodiversity loss at an unprecedented rate and urgent action is needed worldwide. Fossil fuel extraction contributes directly to two of the main causes of biodiversity decline: habitat destruction and pollution, with offshore oil and gas drilling contributing directly to both. In the Bering Sea—which is one of seven OCS leasing areas and a highly productive ecosystem essential to the marine food web—drilling would introduce pollution and worsen climate-related stresses such as habitat fragmentation. This threatens biodiversity and weakens the ocean’s capacity to store carbon, undermining broader climate stability. New leasing activity under the 11th National Five-Year OCS Oil and Gas Program risks further eroding marine protections. It could also jeopardize the 30x30 target set under the Kunming-Montreal Global Biodiversity Framework, which seeks to conserve 30% of land and seas by 2030.
