June 30, 2010
Ms. Renee Orr, Chief Leasing Division
Minerals Management Service
4010 381 Eldon Street
Herndon, VA 20170-4817
Re: 2012-2017 Five year Outer Continental Shelf Program
Dear Ms. Orr:
The Resource Development Council (RDC) appreciates the opportunity to submit comments on the 2012-2017 five-year Outer Continental Shelf (OCS) program. RDC urges the Minerals Management Service (MMS) to move forward expeditiously with the 2012-2017 program.
RDC is a statewide membership-funded organization founded in 1975. Our membership is comprised of individuals and companies from Alaska’s oil and gas, mining, timber, tourism, and fisheries industries, as well as Alaska Native corporations, local communities, organized labor, and industry support firms. RDC’s purpose is to link these diverse interests together to encourage a strong, diversified private sector in Alaska and expand the state’s economic base through the responsible development of our natural resources.
RDC supports including in the five year program lease sales in the Beaufort and Chukchi Seas that were withdrawn from the 2007-2012 program. These lease sales and subsequent exploration activities should be allowed while additional studies are conducted. Moreover, RDC does not support withdrawing the North Aleutian Basin from future lease sales. There are 23 local governments and Aleutian tribal councils in favor of oil and gas exploration in the North Aleutian Basin. A stringent permitting process and mitigation measures would protect commercial and subsistence fisheries in the region, where communities are shrinking under the stress of a weak economy and chronically high unemployment.
RDC supports offshore exploration in the Alaska OCS because it is confident operations can occur safely. However, since recent events in the Gulf of Mexico, opponents of offshore drilling are calling for a freeze on new exploration and development in Alaska and elsewhere. RDC sharply disagrees, because while the tragedy in the Gulf reminds us that there is always some risk of developing our energy resources, we cannot simply ignore our need for oil and gas until the nation fully transitions to other energy sources in the future. Moreover, there are important distinctions between drilling in the deep waters of the Gulf of Mexico and the relatively shallow waters offshore Alaska. In the Chukchi and Beaufort Seas, exploration would occur in water approximately 150 feet in depth, compared to 5,000 feet or more in the Gulf. The wells being drilled in the deep waters of the Gulf are also significantly different than those that would be drilled in Alaska, not only in water depth, but down-hole pressure. The pressure encountered in deepwater drilling is multiple times greater than in Alaska where wells would be drilled to a depth of 7,000 to 10,000 feet, compared to 20,000 feet in the Gulf. With the lower pressure, the safety margin in Alaska drilling is much greater and drillers would have significantly more time to identify and respond to an event. In addition, the relatively shallow water depth would allow blowout preventers to close much more rapidly than those in deep water.
There has never been a blowout in the Alaska or the Canadian Arctic. Thirty wells have been drilled in the Beaufort and five in the Chukchi – all without incident. These wells were drilled in the 1980s, utilizing older technology compared to what exists today.
I would also like to point out that vigorous opposition from national environmental groups has led to administrative and court challenges on almost every front on Shell’s plans to drill current leases in the Chukchi and Beaufort Seas. Those challenges were summarily rejected, including a decision from the Ninth Circuit this spring rejecting the meritless claims of multiple environmental groups. Moreover, Shell’s prevention and response plans meet or exceed stringent requirements to operate in Alaska.
Advances in technology provide an additional measure of confidence in Alaska drilling. Energy development in Alaska is subject to in-depth analysis by federal law, a stringent permitting process and oversight by state and federal agencies. In every instance, development is preceded by extensive studies. The North Slope and the offshore are now perhaps the most studied energy basins in America. MMS has spent more than $300 million on studies in Alaska and in the past decade the agency has funded over 250 studies here, with the majority of those focused on the Beaufort and Chukchi Seas.
RDC recognizes that subsistence whaling is vitally important, both economically and culturally to North Slope villages, and that commercial fishing historically has been the primary industry in the North Aleutian Basin. Industry and government working together have the ability to protect subsistence and fishery resources while producing needed domestic energy for the nation. Strong regulatory oversight, combined with other mitigation measures, can be employed to protect all resource and subsistence users.
To help address local socio-economic impacts, RDC strongly supports sharing federal royalty payments from production in federal waters with coastal states and local communities. Such a measure is critical to local Alaska communities in the Arctic and the North Aleutian Basin. Revenue sharing would significantly benefit local communities and facilitate a healthy partnership among federal, state and local agencies.
The responsible development of potentially immense oil and gas deposits in the Arctic would significantly boost Alaska’s economy, extend the life of the trans-Alaska oil pipeline, improve the economic viability of the proposed natural gas pipeline from the North Slope to the Lower 48 and reduce America’s reliance on foreign energy.
A comprehensive energy plan for the nation must include Alaska, which accounts for over 30 percent of the nation’s technically recoverable oil and gas resources. The Alaska OCS is an important future source of U.S. energy supply with an estimated 27 billion barrels of oil and 132 trillion cubic feet of natural gas potentially in place. By comparison, total production from the North Slope over the past 32 years has been approximately 16 billion barrels. In addition, the potential recoverable reserves offshore Alaska is more than all the current total proven U.S. oil reserves of approximately 21 billion barrels. Alaska would have the ninth largest oil resources in the world ¬– ahead of Nigeria, Libya and Norway – if access is granted to these potential reserves.
Yet despite this potential, the U.S. chose to import over 77.8 billion barrels of oil over the last 20 years. This past year alone the nation imported nearly 70 percent of the oil it consumed – at a great cost. Not developing its reserves in Alaska and those elsewhere in the American OCS makes no sense from an economic and energy security stand point. A recent report from the National Association of Regulatory Utility Commissioners revealed that not developing America’s domestic offshore resources could lead to a dangerous energy crisis. American oil production is projected to decrease by 9.9 billion barrels within the next 20 years, nearly a 15 percent annual decrease from current levels. Meanwhile, imports of oil from OPEC are projected to increase by 4.1 billion barrels, nearly 19 percent – and at a cost of $607 billion.
The cost of not developing additional U.S. reserves would put a huge burden on the economy, resulting in the loss of 13 million jobs in energy intensive industries and a decrease in real disposable income of $2.34 trillion. Gross domestic product would decrease by an estimated $2.36 trillion.
Given its potential for immense recoverable reserves and enormous economic benefits to the state and nation, the Alaska OCS should be opened to responsible development. The Alaska OCS has the potential to sharply increase throughput in the oil pipeline, which is currently operating at one-third of its peak capacity reached in the late 1980s. Without new significant discoveries of oil, the pipeline could be uneconomic to operate at some point after 2020. In addition, OCS gas reserves would significantly improve the long-term economic viability of the proposed gas pipeline from the North Slope to the Lower 48 – a clean energy priority of the Obama administration. To become a reality, the pipeline requires additional gas reserves beyond what has already been discovered onshore.
With its enormous potential reserves, the OCS can sustain Alaska’s economy for generations, creating tens of thousands of jobs and generating hundreds of billions of dollars in federal, state and local government revenues. Currently there are more than 108,000 Alaskan jobs tied to the discovery, production and shipment of Alaskan oil and natural gas, accounting for more than 15 percent of Alaska’s population. According to a University of Alaska study, OCS production could provide an annual average of 35,000 additional jobs within the state for 50 years and $72 billion in new payroll.
RDC and many Alaskans share President Obama’s view that America needs to conserve more and put new emphasis on renewable and alternative energy. By doing so, the nation can ultimately break its reliance on foreign oil. Yet while America must conserve more and move toward renewable energy, it still needs to pursue new oil and gas production, given the fact it will take decades before renewable energy becomes a dominant energy source. Even with the Obama administration’s goal to decrease dependence on oil, it is projected that fossil fuels will still account for two-thirds of this nation’s energy consumption in 2025.
Where will the oil come from to meet this demand? The OCS is the most logical choice, given its immense potential. If not the OCS, then where? For every barrel of oil not developed domestically, the nation will have little choice but to import another from foreign countries – where weaker environmental regulations often apply. Given economic and geopolitical concerns, that barrel should be produced here in the U.S. – under American laws, regulations and oversight, and by American workers.
Given demand for energy will rise as the economy recovers, America must continue to pursue new oil and gas development, even as the nation slowly transitions to the new energy sources of the future. Increased emphasis on renewable energy should not preclude or require less oil and gas development. America needs more of both to offset declining production and reduce its reliance on foreign oil. Development of OCS oil and gas resources will buy America the time it needs to develop the alternative and renewable energy resources that will someday assist in the nation achieving energy independence.
It is vital that our nation’s abundant energy resources be fully utilized for compelling economic and energy security reasons. RDC encourages MMS to move forward with the 2012-2017 program, including the Chukchi and Beaufort Seas lease sales originally scheduled under the previous five-year program.
Thank you for the opportunity to provide comments on the 20012-2017 OCS program.
Sincerely,
Resource Development Council for Alaska, Inc.
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