November 6, 2007
NE NPR-A Supplemental IAP/EIS Comments
ENSR Corporation
1835 South Bragaw Street, Suite 490
Anchorage, Alaska 99508
Dear NE NPR-A Planning Team:
On behalf of the Resource Development Council for Alaska, Inc. (RDC), I am writing to urge the Bureau of Land Management (BLM) to adopt Alternative C as the Preferred Alternative in the Final Supplemental Integrated Activity Plan/Environmental Impact Statement (IAP/EIS) for the Northeast National Petroleum Reserve-Alaska (NE NPR-A).
RDC is a statewide, non-profit, business association comprised of individuals and companies from Alaska’s oil and gas, mining, timber, tourism and fisheries industries. Our membership also includes Native regional and village corporations, local governments, organized labor and industry support firms. RDC’s mission is to help grow Alaska’s economy through the responsible development of the state’s natural resources.
As we have consistently stated in earlier comments regarding NPR-A, RDC believes full leasing should occur in the planning area. Three decades of oil and gas activity in the Arctic clearly demonstrate that industry has the capability to operate throughout Alaska’s North Slope while maintaining high standards of safety and environmental sensitivity.
New advances in technology have greatly reduced industry’s footprint, allowing for the preservation of more surface acreage within the oil fields for wildlife habitat. In addition to technological advances, scientific studies conducted since 1998 have greatly improved the agency’s knowledge of the biological resources within the planning area.
New exploration and production technologies will be best employed if industry is allowed to explore those lands within the petroleum reserve with the highest prospects for a commercial discovery. 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 important that BLM provide access to the Northeast planning area’s best prospects. Alternative C would provide such access. North Slope oil and gas deposits have occurred almost exclusively within a 25-mile strip of the Beaufort Sea coastline. Alternative C would open acreage within this belt – acreage that could hold significant deposits.
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 the 1998 plan for the Northeast area, but was open to leasing in the amended 2005 plan. It is considered to be among the most oil-rich acreage in NPR-A, perhaps containing two billion barrels of oil. RDC recognizes this area contains large populations of waterfowl and caribou and is coveted by local residents for subsistence hunting.
While Alternative C would open 100 percent of the Northeast area’s 4.6 million acres to oil and gas exploration, permanent facilities would be prohibited on more than 1,113,000 acres. A variety of protective measures and stipulations would be employed to mitigate impacts of energy development and other land uses on resources in the planning area. These protective measures would provide BLM flexibility to adopt management decisions to uncertain and changing environmental conditions, and provide more consistent management across the entire northern portion of NPR-A.
Alternative C would retain the setbacks around streams and lakes provided by the 1998 IAP/EIS and it would establish new setbacks north and east of Teshekpuk Lake. It would also utilize performance-based stipulations and mitigation measures.
RDC continues to maintain its support for Alternative C. However, it also recognizes Alternative D has merit as a reasonable compromise that provides access to much of NPR-A’s most prospective acreage while providing measures to mitigate impacts. Alternative D should be adopted as the Preferred Alternative, should Alternative C be eliminated in the decision-making process.
While Alternative D would open 95 percent of the Northeast area to oil and gas exploration, permanent facilities would be prohibited on more than 1,451,000 acres. Management practices would emphasize consultations with local residents and coordinated scientific studies to protect wildlife habitat, subsistence use areas, and other resources. Under Alternative D, Teshekpuk Lake (approximately 211,000 acres) would be indefinitely deferred from leasing. This deferral would preclude exploratory drilling and pipeline construction.
Alternative D makes available approximately 389,000 acres that were unavailable in the 1998 Record of Decision. This acreage is within the area of highest oil and gas potential in the Northeast planning area, and is within the Teshekpuk Lake Special Area. A number of protective measures have been developed as requirements and standards to protect important resources and subsistence activities.
While RDC supports reasonable mitigation measures, future leasing, exploration and development could be discouraged by inefficient costly requirements that duplicate and contradict existing standards and regulations. Mitigation measures should be science-based and cost efficient. They should not include arbitrary requirements or subjective terms open to wide-ranging interpretations. Moreover, many of the proposed measures appear to transfer BLM responsibilities to the lessee, compounding expenses of new oil and gas activities.
With regard to controlling the expense of proposed mitigation measures, RDC recommends that BLM identify where administrative, operational and cost efficiencies can be realized on various monitoring programs and research requirements. In some instances, companies should be encouraged to share mitigation efforts when they agree to coordinate and collaborate on specific projects and programs. It would be helpful if BLM could identify when and how companies could share efforts and compliance requirements.
Alaska’s oil and gas industry continues to innovate and invest in environmentally-sound business practices. It operates under the most advanced and stringent regulations and oversight in the world. Under this set of circumstances, it makes sense to open the entire Northeast planning area for leasing, or at the very least, the areas outlined under Alternative D.
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, employment and oil and gas production would likely be greater under Alternative C than under the other alternatives.
Thank you for the opportunity to provide comments on the Draft Supplemental IAP/EIS.
Sincerely,
Resource Development Council for Alaska, Inc.
