On August 16, the White House Council on Environmental Quality (CEQ) issued a report (CEQ Report) summarizing the findings of a thirty-day review of the U.S. Department of Interior (DOI) Minerals Management Service’s (MMS)[1] environmental polices for oil and gas exploration and development in the Outer Continental Shelf (OCS). CEQ found that MMS’s reliance on the “tiering process” (where prior programmatic environmental reviews are incorporated into later site-specific analyses) was not transparent and led to confusion and concern regarding whether MMS sufficiently evaluated and disclosed environmental impacts.