November 9, 2011
Ms. Sharon Seim
Arctic National Wildlife Refuge
101 12th Avenue, Room 236
Fairbanks, AK 99701-6237
Dear Ms. Seim:
The Resource Development Council (RDC) is writing to express its opposition to Alternatives C and E in the Draft Revised Comprehensive Conservation Plan (CCP) for the Arctic National Wildlife Refuge (ANWR). The 1002 area of ANWR should not only continue to be excluded from Wilderness designation, it should be opened to responsible oil and gas exploration and development. RDC strongly opposes any alternative that encumbers future oil and gas development on the coastal plain. The Service should develop a new alternative that recommends opening the 1002 area to oil and gas exploration and development.
RDC is an Alaskan business association comprised of individuals and companies from Alaska's oil and gas, mining, forest products, tourism, and fisheries industries. Our membership includes all of the Alaska Native Regional Corporations, local communities, organized labor, and industry support firms. RDC's purpose is to expand the state's economic base through the responsible development of our natural resources.
RDC is advocating for Alaska’s and, indeed, our nation’s interests in urging the Service to recommend to Congress that the 1002 area be opened to responsible oil and gas exploration and development, as was recommended by the Department of Interior over 20 years ago. RDC is strongly opposed to new federal Wilderness and wild and scenic river designations in ANWR and the mere implication of such consideration is inconsistent with promises that were made in ANILCA. In our view, any such designations are in violation of the “no more” clauses in ANILCA and the intent of the 1002 area and Alaska statehood.
The 1002 area was excluded from the existing Wilderness designation in a compromise struck under the 1980 Alaska Lands Act. In exchange, Congress doubled the size of the refuge and designated eight million acres outside the 1002 area as Wilderness. In recognizing the 1002 area’s enormous oil and gas potential, Congress mandated a study of its petroleum resources, as well as its wildlife and environmental values. In 1987, the Department of the Interior concluded oil development would have minimal impact on wildlife and recommended the 1002 area be opened. In 1995, Congress voted to open the area to exploration, but President Clinton vetoed the measure.
Under ANILCA, the Service has a mandate to periodically revisit the issue of oil and gas development within the 1002 area. In our view, the mandate is clearer than the authority the Service claims to have on revisiting the wilderness suitability and wild and scenic river eligibility issues. In addition, there has been considerable improvements in oil and gas exploration and development technology that has greatly reduced industry’s footprint in the many years since the original study was completed. These improvements would make it possible to develop the 1002 area’s energy reserves while directly utilizing only a fraction of the area.
We now have a Draft CCP that proposes several alternatives that include new Wilderness designations for ANWR while refusing to even consider oil and gas development in the 1002 area. The mere fact that an alternative requires legislative implementation, such as oil and gas activity in the 1002 area, does not automatically establish it as beyond the domain of what is required for discussion and consideration in the CCP.
Moreover, ANILCA provides that the purpose of Section 1002 “is to provide for a comprehensive and continuing inventory of the assessment of fish and wildlife resources….an analysis of the impacts of oil and gas exploration development and production, and to authorize exploratory activity within the coastal plain.” The statute goes on to provide that the Secretary of the Interior must provide Congress with recommendations “with respect to whether further exploration for, and the development and production of, oil and gas within the coastal plain should be permitted and, if so, what additional legal authority is necessary to ensure that the adverse effects of such activities on fish and wildlife, their habitats, and other resources are avoided or minimized.” Therefore, in our view, the Service is required by statute to evaluate the impacts of oil and gas exploration. In addition, it is a violation of NEPA not to do so, given the law provides that federal agencies must “study, develop, and describe appropriate alternatives to recommended courses of action in any proposal which involves unresolved conflicts concerning alternative uses of available resources.” There is certainly a conflict over competing uses of the 1002 area. As a result, the Service must consider oil and gas development as an alternative.
As noted earlier, any action that would preclude oil and gas development in the 1002 area would be in conflict with congressional intent surrounding Alaska statehood. Alaska became a state based on the congressional intent that through development of its natural resources it would be able to sustain its economy and pay its own way. Early statehood bills failed in Washington, and ultimately it was the discovery of oil that convinced Congress Alaska could sustain itself as a state.
Maintaining the option for future oil and gas development in the 1002 area is of vital importance to Alaska and anyone who is truly supportive of increasing domestic energy production and reducing foreign imports. A federal Wilderness designation over the 1002 area would preclude development of North America’s most prolific onshore oil and gas prospect and compromise Alaska’s economy for generations to come. Expanded federal Wilderness in ANWR would also violate the “no more clause” of ANLICA. Alaska contains 58 million acres of federal Wilderness, which is more than half of all congressionally-designated Wilderness in America. Not a single acre of this Wilderness would be disturbed by oil and gas activity in the 1002 area.
This is an interesting time for this debate to be occurring, given chronically high unemployment and critical structural problems with the US economy, including staggering government debt and an alarming trade deficit, largely a result of imported oil. What we do need is more economic opportunities and increased domestic oil and gas production. Opening the 1002 area to responsible oil and gas development would be a big step in the right direction, providing a huge and lasting stimulus to the economy and billions of dollars in new revenues to the federal government – all with virtually no expense to government!
Oil development in the 1002 area would provide a safe and secure source of oil for the nation for decades. It would create tens of thousands of jobs throughout the country and refill the Trans- Alaska Pipeline System (TAPS), existing infrastructure that is currently operating at only one-third of its original capacity.
The biggest threat to Alaska’s economy is the sharp ongoing decline in TAPS throughput, which has fallen from 2.1 million barrels per day (bpd) in 1988 to an average of 568,000 bpd from January through August of this year. Four years ago, more than 734,000 bpd were flowing through the pipeline. Both President Obama and Governor Sean Parnell have stated that increasing TAPS throughput is a national priority and in the nation’s best interest.
With advances in technology, it is possible to develop the 1002 area’s energy reserves without significant disturbance to wildlife. In fact, wildlife populations have grown or remained stable in other areas of the North Slope where oil development is already occurring. One example at Prudhoe Bay shows the central arctic caribou population has grown from 5,000 animals in 1970 to more then 66,000 animals today.
Oil and gas development can and does coexist with wildlife in America’s national wildlife refuges. In fact, there are numerous examples, including the Kenai National Wildlife Refuge in Southcentral Alaska. This refuge is heavily visited by Alaskans and by tourists from across the world, yet it is the site of the first major discovery of oil and gas in Alaska. Oil and gas production have been occurring within the refuge for more than 50 years, and wildlife populations have remained healthy.
Alaskans statewide strongly support exploration and development in the 1002 area of ANWR. In fact, polling has consistently shown that more than 70 percent of Alaskans support development of energy resources beneath the 1002 area. In addition, the Alaska Federation of Natives, the North Slope Borough, and the Arctic Slope Regional Corporation support development. Local residents and the Inupiat people who actually live adjacent to the 1002 area also support development. This support should be given considerable weight and should convince the Service to keep the 1002 area free of any federal Wilderness designation.
With regard to wild and scenic river designations, RDC remains opposed to additional designations in ANWR, which already includes three designated rivers. As with the wilderness proposals, we consider additional designations excessive and unnecessary as current management practices already provide sufficient protection of river corridors.
In conclusion, the 1002 area of ANWR should be opened to responsible oil and gas exploration and development. RDC strongly opposes any alternative that encumbers the potential for oil and gas development on the coastal plain. The Service should develop a new alternative that recommends opening the 1002 area to oil and gas exploration and development. Such action would create thousands of jobs, stimulate the economy, reduce America’s dependence on foreign oil, and generate much-needed ongoing revenues to the federal government.
Section 1002 of ANILCA was created in the spirit of compromise by members of Congress, as was the “no more clause,” which implied “enough is enough” with regard to Alaska’s vast conservation system units and federal Wilderness designations. A Wilderness designation across the 1002 area would not only violate this compromise, it is unnecessary and is not in the best interests of America.
Sincerely,
Resource Development Council for Alaska, Inc.
