View RDC's Comment Letter

Deadline for Comment was August 27, 2012

Overview:
The Environmental Impact Statement (EIS) and Clean Water Act Section 404 permitting processes for ExxonMobil’s Point Thomson Project have been underway for nearly three years, and for the most part, the EIS process has concluded. The company continues to focus on the Clean Water Act 404 permitting process. Part of this process involves a public comment period – the third undertaken in the last three years of continuous environmental assessment and agency reviews of the Point Thomson Project.

The Army Corps of Engineers and other federal agencies are considering whether to approve the project as proposed or to impose new conditions or changes. After a year already lost to permitting delays, ExxonMobil is requesting that the Corps move forward with approval of the project by issuing the 404 permit in a timely fashion. Issuance of the permit by the Corps by mid-October 2012 is critical to allow construction to commence this winter. If this window is missed, substantial work on the project this winter would be jeopardized and first production would be delayed by at least one more year. The project would employ over 1,000 people this winter if the permit is issued by October.

Point Thomson is a remote field on the Beaufort Sea coastline 60 miles east of Prudhoe Bay and two miles from the Arctic National Wildlife Refuge. The field contains an estimated eight trillion cubic feet of natural gas and 200 million barrels of condensate. Point Thomson represents approximately 25 percent of the North Slope’s known natural gas resources. Development of Point Thomson is essential to Alaska natural gas commercialization. Besides the operator, ExxonMobil, other major partners include BP, ConocoPhillips, and Chevron.

The project will use long-reach directional drilling from onshore pads to recover offshore resources. The proposed project includes three pads and five wells, with a central pad supporting production facilities, infield roads, pipelines, an airstrip, and a gravel mine site. A common carrier pipeline will be constructed for transporting hydrocarbon liquids 22 miles west to the Badami pipeline.

Action requested:
RDC encourages its members to participate in the process by submitting comments encouraging the Corps of Engineers approve the Point Thomson project as proposed and to issue the Clean Water Act Section 404 Permit in a timely manner to allow substantial work to proceed this winter and for production to begin in 2016.

Deadline for Comment was August 27, 2012

Submit comments to:
Mail:
Anchorage Regulatory Division (1145)
CEPOA-RD Box 6898
JBER, Alaska 99506-0898

Email: harry.a.baij@usace.army.mil

Points to consider in your comments:

• Permit issuance by the Corps by mid-October is critical to allow construction to commence this winter. If this window is missed, then first production will be delayed by at least one more year.
• ExxonMobil has committed to the State in the recently announced settlement agreement to initiate production at Point Thomson by the winter of 2015/2016. Start of construction this winter is necessary to meet this important commitment.
• If ExxonMobil’s scheduled construction period begins as planned this winter, over 1,000 construction jobs on the North Slope will be created.
• The Point Thomson Project will provide significant and wide-ranging benefits to Alaska businesses in the form of new business opportunities, as well as new revenues to the state and local governments, increased throughput for the Trans-Alaska oil pipeline, and increased business activity and revenue for the private sector.
• The Point Thomson Project contains approximately 25% of known North Slope natural gas and is strategically important to the development of Alaska natural gas.
• With an estimated eight trillion cubic feet of natural gas, Point Thomson will be a key element in any future gas pipeline.
• The proposed Point Thomson Project provides the safest, most environmentally responsible solution to developing Point Thomson’s resources in a timely, cost-effective manner.
• The Point Thomson Project’s proposed design and execution plan includes significant mitigation to minimize environmental impacts. The plan avoids or minimizes impacts on high value wetlands, habitat and hydrology.
• The proposed Project has eliminated the need for construction of major facilities in marine waters by adopting an innovative barge-bridge system for offload of sealift modules.
• A combination of summer coastal barging, winter ice roads, aviation, and infield roads are essential to safe and efficient operations at Point Thomson. The coastal barge route is located inside barrier islands and away from the main fall migration corridor for bowhead whales.
• ExxonMobil will implement comprehensive mitigation measures to minimize impact on tundra, wildlife, aquatic resources, and subsistence activities. Project design and operational features will be implemented to protect polar bears and humans.

Deadline for Comment was August 27, 2012