Almost never has and probably never will again.
I really wish I didn't believe what I just wrote :(
Reading this today just reinforces that belief.
http://www.salon.com/news/opinion/glenn_greenwald/2010/06/03/salazar/index.html........"The excuse the Bush administration gave for failing to conduct that review is the same one Obama gave in his press conference. As the court put it: "MMS argues that the strict timelines in OCSLA indicate that an EIS is not a feasible option at the exploration stage. The agency only has thirty days to approve or disapprove of an exploration plan" and officials "argue that thirty days is not enough time to generate a full EIS." The court categorically rejected that excuse (emphasis added):
The agency may be correct that it is difficult for an agency to conduct a full EIS in only thirty days, but its argument that OCSLA precludes such a result is unconvincing. There is flexibility built into the regulatory scheme so that the agency can perform its full duties under NEPA. The thirty-day clock begins to run only when an exploration plan is deemed complete. 30 C.F.R. § 250.233(a). If the agency is able to identify gaps before that point, then it can request that information be added before the proposal is finalized. See 30 C.F.R. § 250.231(b). Additionally, at the end of the thirty-day review period, the agency may opt to require modifications to an EP if there are concerns that it does not comport with environmental standards. 30 C.F.R. § 250.233(b). These options give the agency additional time to consider a plan and compile an environmental impact statement, if necessary. To say simply that the agency only has thirty days to complete a full EIS is misleading.
The excuse which the court condemned as "misleading" is exactly the one Obama and his aides have been repeatedly making for why they issued exemptions to BP: namely that, as the President put it, "under current law, the Interior Department has only 30 days to review an exploration plan submitted by an oil company. That leaves no time for the appropriate environmental review." As a result, the court found that MMS's approval of Shell's drilling plan (including the exemptions it issued) violated NEPA, and thus invalidated the approval and ordered MMS to re-review the proposal in compliance with the law. That decision was issued in November, 2008 -- before the Obama administration even began -- so the notion that Obama Interior officials believed they only had 30 days to conduct a review, and that it therefore was forced to issue exemptions to BP, lacks credibility, to put that mildly.".......
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Worth the time to read the whole post.