Return to 2008 Action Alerts
March 25, 2008
Yukon Flats EIS Project Office
c/o ENSR
1835 S. Bragaw, Suite 490
Anchorage, AK 99508
To Whom It May Concern:
On behalf of the Resource Development Council for Alaska, Inc. (RDC), I am writing to support the proposed land exchange in the Yukon Flats National Wildlife Refuge between Doyon Limited and the U.S. Fish and Wildlife Service. RDC strongly supports the Proposed Action Alternative and Alternative 1.
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.
RDC has followed this issue since its inception and supported the land exchange in a previous comment period. With release of the Draft Environmental Impact Statement (DEIS), RDC continues to believe the proposed land exchange is in Alaska’s best interest.
The exchange would allow the Service to achieve its conservation goals and consolidate land ownership. It would allow the agency to acquire many of the highest-priority fish and wildlife habitats on Doyon lands. In fact, as stated in the DEIS, “there would be a net gain of water bodies and fish habitat, high value waterfowl habitat, wildlife habitat, aquatic mammal species, known cultural resource sites, and lands for subsistence use.” The Service would end up administering more land, with consolidation of surface ownership and reduced refuge boundaries.
The land exchange would allow Doyon to consolidate its holdings within the Yukon Flats as well, improving the economics of drilling for oil and gas. While the entire flats show favorable signs of oil and gas, the highest petroleum potential lies under land proposed for exchange.
It is important to recognize that Doyon will likely proceed with oil and gas development on its existing lands inside the refuge, even if the land swap does not happen. Under the terms of the Alaska National Interest Lands Conservation Act (ANILCA), Doyon would have the right to cross refuge lands, including the lands that the corporation would have gained in the exchange, to develop the corporation’s oil and gas interests. After all, the Yukon Flats Refuge was established after Doyon selected its lands -- for the purpose of future development. Before the refuge was created, Doyon recognized the potential for significant oil and gas discoveries in the Yukon Flats Basin and worked with villages in the region to maximize future development of the resource.
Regardless of whether oil and gas is ever discovered, the land exchange is a gain for the national wildlife refuge system. Doyon would relinquish a larger area of surface land than it would gain, including high-value habitat. Under the proposed trade, Doyon would turn over 150,000 acres rich in fish and game resources. In exchange, Doyon would receive oil and gas rights to 200,000 prospective acres. However, Doyon would have surface rights to less then 110,000 of those acres, most of which is in the uplands with lesser habitat values. The remaining acreage would be reached only by directional drilling. If Doyon discovers and produces oil and gas on the lands acquired through the exchange, the Service would receive a production payment equal to 1.25% of the value at the wellhead and a commitment from Doyon to sell up to 120,000 acres more land to the Service. In addition, Doyon would reallocate 56,000 acres of remaining entitlement within the refuge to locations outside the refuge.
The benefits of the land exchange to Doyon, its shareholders, the State of Alaska and the nation are significant. The Yukon Flats could hold large quantities of natural gas and oil. The U.S. Geological Survey offers a mean estimate of 5.5 trillion cubic feet of recoverable natural gas and 173 million barrels of recoverable oil. A recent private-sector assessment by Petrotechnical Resources of Alaska estimated the area could hold 300 million to almost 1 billion barrels of oil and 15 trillion cubic feet of natural gas. The area is potentially another energy province on the scale of the Cook Inlet Basin and could hold two Alpine-size oil fields.
If commercial discoveries of oil and gas are confirmed, billions of dollars would be pumped into Alaska’s economy. State revenues would grow and new energy supplies would flow into local and energy-hungry Lower 48 markets. The land exchange and subsequent discovery of energy resources would allow for the creation of a long-term economic base in an economically-disadvantaged part of rural Alaska. Development could create 1,000 or more good-paying jobs. It would help fulfill the promise of the Alaska Native Claims Settlement Act (ANCSA) to enhance social and economic well-being of Native people, creating jobs and other opportunities for Doyon shareholders.
Other benefits include village and regional Native corporation revenue sharing under ANCSA, which means more revenue statewide for these entities and their shareholders – Alaska Natives.
At recent public hearings on the EIS, opponents of the proposed exchange claimed it would set a precedent for oil and gas development inside refuges and that such development is incompatible with the refuge. We strongly disagree. First, historical record and reality clearly show responsible development is already occurring in national refuges, including the Kenai National Wildlife refuge in Southcentral Alaska. Second, oil and gas development can take place in compliance with strict state and federal laws and regulations, mitigating impacts and protecting surrounding resource values. In fact, if Doyon is successful in finding and developing oil and gas, less than one percent of the Yukon Flats would be disturbed, leaving vast areas available for subsistence and other multiple-use activities.
In concluding, while the EIS may have some minor deficiencies, RDC believes it represents a comprehensive and thorough analysis. The exchange is certainly in the best interest of Alaska and the nation. It will benefit Doyon shareholders and is a win-win for the refuge and Doyon. RDC strongly supports the land exchange and encourages the Service to immediately move forward with the Proposed Action Alternative or Alternative 1.
Thank you for the opportunity to present comments on this important issue.
Sincerely,
RESOURCE DEVELOPMENT COUNCIL
For Alaska, Inc.
