June 5, 2008
Mr. Tom Lonnie
Alaska State Director
U.S. Bureau of Land Management
222 W. 7th Avenue
Anchorage, Alaska 99513-7504
Re: NE NPR-A Supplemental Final IAP/EIS Comments
Dear Mr. Lonnie:
On behalf of the Resource Development Council for Alaska, Inc. (RDC), I am writing to express disappointment with 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 natural resources.
Specifically, RDC is disappointed the Bureau of Land Management (BLM) deferred from leasing for at least ten years approximately 430,000 acres in the onshore areas to the north and east of Teshekpuk Lake. As you know, this is contrary to the previous decision made by BLM for the proposed October 2006 lease sale in this area. The regulations proposed in the Draft Supplemental IAP/EIS under “Alternative D” adequately addressed environmental, subsistence and cumulative impact issues. Therefore, RDC believes it was unnecessary for BLM in the final IAP/EIS to defer additional highly prospective acreage from potential future lease sales.
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. 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.
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 BLM provide access to the Northeast planning area’s best prospects. North Slope oil and gas deposits have occurred almost exclusively within a 25-mile strip of the Beaufort Sea coastline. Acreage within this belt that could hold significant deposits, should be open, not closed to development.
The area deferred in the FEIS is considered to be among the most oil-rich in NPR-A. RDC recognizes this area contains large populations of waterfowl and caribou and is coveted by local residents for subsistence hunting. However, a variety of protective measures and stipulations outlined in both Alternative D and C in the previous Draft Supplemental IAP/EIS would have mitigated impacts of energy development on other land uses and resources in the planning area. Both alternatives would have retained the setbacks around streams and lakes provided by the 1998 IAP/EIS and established new setbacks north and east of Teshekpuk Lake.
In its earlier comments on this issue, RDC supported Alternative C in the Draft Supplemental IAP/EIS, but also noted Alternative D had merit as a reasonable compromise that would provide access to much of NPR-A’s most prospective acreage while providing measures to mitigate impacts. RDC noted, “Alternative D should be adopted as the Preferred Alternative, should Alternative C be eliminated in the decision-making process.” However, RDC must now take exception to the modified Alternative D, where deferred acreage has nearly tripled from the original 219,000 acres, despite the many protective measures and restrictions provided
under the draft supplemental alternatives.
In conclusion, RDC finds it disturbing BLM would essentially close additional attractive areas for energy exploration and production inside a petroleum reserve at a time of sharply rising energy prices, and when there is an ever-increasing need for new domestic energy production. In fact, we would argue BLM has a moral obligation to open these areas to exploration, given the deteriorating domestic energy situation and the threat high energy prices pose to Americans and the economy. In addition, industry has invested significant resources into a large 3-D seismic program in this area and considerable additional resources have been invested to interpret data and prepare for competitive bidding. Apparently this investment may be all for naught, once again signaling to resource industries that Alaska is an expensive and politically-challenged state to do business.
In the best interest of Alaska and the nation, RDC urges BLM to reconsider its recent decision to defer additional highly prospective lands from development.
Resource Development Council for Alaska, Inc.