Comment Deadline is November 6, 2007

View RDC's Comment Letter

Overview:

The Bureau of Land Management (BLM) has released the Northeast National Petroleum Reserve – Alaska Supplemental Integrated Activity Plan/Environmental Impact Statement (IAP/EIS). This supplement addresses a list of issues and contains a range of alternatives regarding the BLM’s administration of public lands within the planning area. These alternatives are essentially unchanged from those analyzed in the Northeast NPR-A Final Amended IAP/EIS and corrects inadequacies in that plan identified in a 2006 decision of the U.S. District Court of Alaska. The Court found that the amended 2006 IAP/EIS failed to fully consider the cumulative effects of oil and gas leasing in the planning area and in the adjacent Northwest NPR-A planning area. The new supplement adds this analysis.

Under the recently-released IAP/EIS, 373,000 acres north and east of Teshekpuk Lake is further evaluated for leasing. This area was off-limits in a 1998 plan crafted by the Clinton administration for the Northeast area of the reserve, but was open to leasing in the amended 2005 plan. This area is considered to be among the most oil-rich acreage in NPR-A, perhaps containing two billion of barrels of oil. The area also contains large populations of waterfowl and caribou. It is coveted by local residents for subsistence hunting.

The four alternatives in the 2007 amendment range from opening 87 percent to 100 percent of the 4.6 million acres of the Northeast planning area to oil and gas exploration and development. While the agency clearly supported increased leasing in the 2005 plan over the 1998 proposal (Alternative A–No Action), the latest version does not indicate which alternative of the four BLM prefers. The alternatives offer two types of mitigation for impacts to resources –  prescriptive to performance-based. Given industry’s track record of coexisting with wildlife on the North Slope and the technological advances of the past decade, which have greatly reduced the development footprint, RDC supports Alternative C, full leasing.

Action Requested: 

RDC urges its members to submit comments encouraging BLM to provide access to the Northeast planning area’s richest oil and gas prospects. Alternative C would provide such access.

Submit written comments to:

Points to consider for your comments:

• Given NPR-A was specifically designated by Congress for the production of energy resources and the need for new oil production has increased, it is vital that BLM provide access to the Northeast planning area’s greatest prospects. Alternative C would provide such access.
• All of the producing fields on the North Slope are located within 25 miles of the coast. Eliminating substantial acreage within this belt could preclude the discovery of a major deposit.
• The areas currently off-limits in Alternative A may contain more than two billion barrels of recoverable oil.
• Industry’s track record on the North Slope and the technological advances of the past decade, which have greatly reduced the development footprint, support full leasing.
• Alternative C would utilize prescriptive to performance-based standards and procedures to mitigate impacts of energy development. In addition, seasonal stipulations and other protective measures would be applied to safeguard sensitive areas. While Alternative C would open 100 percent of the area’s 4.6 million acres to oil and gas exploration, permanent facilities would be prohibited on more than 1,113,000 acres.
• The industry has proven it can operate in a manner that protects the environment. The Arctic wildlife and environment can and will be preserved while petroleum resources are developed. Industry employs a variety of measures and operating procedures to mitigate impacts and protect environmentally sensitive areas.
• Oil and gas development in the petroleum reserve would benefit the economy by creating increased revenues and employment, while enhancing energy and economic security.
• Revenues and employment generated by oil and gas development would be significantly greater under Alternative C than under the no action alternative.
• The Department of Energy estimates the contribution of North Slope crude to domestically produced oil supplies would decline from 18 percent to 14 percent by 2020, but such a decline could be mitigated by opening Northeast NPR-A to oil and gas exploration. Projected production declines could potentially be reversed, depending upon how much additional oil is produced from NPR-A, but potential could be severely compromised if access is not provided to oil-rich areas.
• While opponents claim the changes to BLM’s amended plan are merely cosmetic, the analysis of the increased activity in the 2007 draft expanded and substantially revised consideration of additional measures for minimizing impacts. BLM also considered results of recent scientific studies completed since 2005.
• The 2007 draft also addresses the cumulative impact of increased activity in the Northeast planning area when combined with increased activity in the Northwest planning area.
• The 2007 draft also takes into account issues ranging from climate change and potential Endangered Species Act protections for polar bears to the rising price of oil.
• Authorizing leasing is but a first step in opening an area to oil and gas development.  There will be additional opportunities throughout the process, through the application of numerous permit approvals and other actions, to protect natural resources.  

Comment Deadline is November 6, 2007