RDC Action Alert:
Public Input Solicited On Shell’s Beaufort Sea Drilling Plan
and Oil Discharge Prevention and Contingency Plan

Read RDC's comment lettter

Comment deadlines were December 22 and 23, 2010

Overview:

Alaska’s OCS is again under review and public comments are requested. RDC members are encouraged to provide comments on the Shell’s 2011 Beaufort Sea Exploration Plan, as well as the Oil Discharge Prevention and Contingency Plan (ODPCP). Comments are due December 22 on the exploration plan and December 23 on the ODPCP. Please consider submission to each separately, or if you prefer, comments can be combined to address both topics in one letter.

Submit comments to:

Regional Supervisor, Leasing and Environment
Bureau of Ocean Energy Management, Regulation and Enforcement
3801 Centerpoint Drive, Suite 500
Anchorage, AK, 99503

Comments specific to the exploration plan can be submitted by email to:
CamdenBayEPSEA@boemre.gov

Or by fax to: (907) 334-5242. Comments specific to the ODPCP can be submitted by email to:
AK_OSCP_Comments@boemre.gov

Background:

The Bureau of Ocean Energy Management, Regulation and Enforcement (BOEM) has issued a notice requesting public comments on Shell’s 2011 exploration plan for the Beaufort Sea and an associated supplemental environmental assessment. The agency is also soliciting comments on the Oil Discharge Prevention and Contingency Plan.

BOEM is conducting the supplemental assessment on Shell’s exploration plan to take into account changes the company made to its plan in October in light of the oil spill in the Gulf of Mexico. BOEM will consider “new information” from the Gulf oil spill and examine environmental impacts of new support vessels Shell has added to its project on a standby basis to enhance oil spill response capabilities in the unlikely event of a blowout.

Points to consider in your comments:

• BOEM completed a careful analysis of the impacts of Shell’s proposed Beaufort Sea exploration program, including a detailed cumulative impacts analysis of a multi-well program, and determined that Shell’s plan would have no significant impacts on the marine environment or the marine mammal, bird or fish species common to the Arctic.
• Shell’s 2011 exploration plan has been revised to include provisions to reduce discharges to the marine environment, changes that only bolster the previously approved 2010 exploration plan, which was reviewed and upheld by the 9th Circuit Court of Appeals. In response to local concerns, Shell updated its plans to include using a barge to collect waste such as drilling cuttings and sanitary waste from the drilling vessel, rather than discharging this waste into the sea, as permitted by law.
• As the Anchorage Daily News emphasized in an editorial on December 2, 2010, “Let Shell go to work in 2011 to explore for oil -- and also restore faith in the industry's ability and will to do it right, to tap Alaska's oil and gas treasure while abiding by the highest and environmental and safety standards on the planet. We need the oil. We need the jobs. And we need to provide them while protecting the Arctic environment and its communities.”
• Alaska OCS Development will sustain and promote job growth during a period of high national unemployment, reduce America’s dependence on foreign energy supplies and create additional federal offshore revenues for state and federal governments. New offshore oil production would also reverse declining throughput in the Trans-Alaska Pipeline System, which is now operating at less than one-third capacity.
• According to a study by the University of Alaska’s Institute of Social and Economic Research, new offshore energy production in Alaska would produce an annual average of 35,000 jobs and total payroll of more than $72 billion over the next 50 years.
• In Alaska, approximately 43,454 jobs are supported by the industry. These jobs add $6.1 billion to Alaska’s gross state product, or 16.6 percent of its wealth. The unemployment rate is already up to 8.9 percent in Alaska.
• New offshore oil and gas development in Alaska would also generate thousands of new, high-paying jobs throughout the 50 states, including steel and pipe manufacturers in the Midwest, shipping on the coasts, advanced computer technology in California and Seattle, and union labor for pipeline construction and maintenance.
• Not developing our offshore natural resources is projected to cost energy intensive industries nearly 13 million jobs and cumulatively decrease the nation’s real disposable income by $2.34 trillion, according to a new report issued by the National Association of Regulatory Utility Commissioners.
• Oil and gas are vital components of our nation’s economy and will remain so for the foreseeable future, even as we strive to transition to renewable forms of energy. Domestic energy production must be a priority under any scenario.

Points specific to the Oil Discharge Prevention and Contingency Plan

• Drilling in the Arctic offers distinct differences than deep water exploration in the Gulf of Mexico. The pressure encountered in Gulf deep water drilling is multiple times greater than in Alaska where wells would be drilled in very shallow water.
• Another distinction is that Shell’s proposed exploration program is seasonal in nature. Exploratory drilling would occur only during the summer and fall open water season.
• In light of the Gulf of Mexico oil spill, Shell has taken unprecedented steps to bolster its response capabilities in the highly unlikely event of a blowout.
• Shell’s oil spill contingency plan is robust and includes capabilities for the recovery of a “worst case” discharge. Oil spill response personnel, vessels and equipment will all be pre-positioned in the area to respond immediately to any oil spill event.
• Shell is well prepared to prevent any well control event. Well control is the primary focus of all of Shell’s exploration drilling plans. Every activity is geared toward maintaining well control and integrity. Shell will deploy the latest and best available technologies to carry out its program.
• Shell’s exploration and Oil spill contingency plans were the subject of extensive public review and comment prior to being approved by both federal and state regulators. Both plans meet or exceed all federal and state regulatory standards.
  

Comment deadlines were December 22 and 23, 2010