December 21, 2011

Mr. Harry Baij
Department of the Army
U.S. Army Engineer District, Alaska
Regulatory Division
P.O. Box 6898
JBER, Alaska 99506-0898

Re: Point Thomson Project EIS

Dear Mr. Baij:

The Resource Development Council (RDC) is writing in support of Alternative B of the Point Thomson Draft Environmental Impact Statement (DEIS).

RDC is a statewide organization made up of all resource sectors, business associations, labor unions, Native corporations, tourism providers, local governments and individuals. RDC’s purpose is 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 strongly supports the advancement of the Point Thomson project, which is essential to the success of the Alaska gas pipeline project – a major clean-energy priority of the Obama administration. Point Thomson contains an important component of gas volume to be moved by an Alaska gas pipeline and accounts for approximately 25 percent of known North Slope gas reserves.

Development of Point Thomson resources will help meet domestic energy needs, reduce dependence on foreign sources, and increase throughput in TAPS, which is currently operating at one-third capacity. In addition, this multi-billion dollar project will provide hundreds of new jobs, additional tax revenues to local, state and federal governments, and help boost the private sector economy in Alaska and the Lower 48. In fact, Point Thomson development and subsequent production will serve as a lasting economic stimulus with virtually no cost to the federal government.

RDC urges the Corps to adopt Alternative B as the preferred alternative. Alternative B provides the safest, most environmentally-responsible option for Point Thomson’s development. It minimizes the environmental footprint by incorporating a combination of summer coastal barging, winter ice roads, aviation, and in-field gravel roads. These features are essential to the project’s safe and efficient operations.

Alternatives C, D, and E in our view will pose a larger environmental impact, compromise safety, and will make it more difficult to respond to an emergency. For example, alternatives C and D prohibit barging, which will result in increase truck traffic. Alternative C will leave a larger tundra footprint from a 44-mile road to the Prudhoe Bay road system, which will require hundreds of additional acres of gravel and five mines. The current North Slope experience at Alpine and Badami demonstrates that a gravel road is not necessary to support Point Thomson.

In contrast, barging has long been established as a safe and efficient mode of transportation for goods, supplies, and equipment throughout the remote Arctic. Over 185 barge trips have occurred to Point Thomson without adverse impacts to the environment, marine mammals, or subsistence. Since 2008, ExxonMobil has conducted safe barging operations in accordance with the Alaska Eskimo Whaling Commission Conflict Avoidance Agreement and in direct consultation with local whaling communities. Moreover, barge routing occurs outside of the main fall migration corridor for bowhead whales. Access to Point Thomson by the existing modes of transportation – barging, ice roads, in-field roads and aviation – are sufficient, provided they are available.

In addition, Alternative C would move the export pipeline inland and double its length from 22 to 44 miles.

RDC also has major concerns with Alternative E, which proposes to eliminate infield gravel roads and shorten a vital airstrip, which would serve a critical role in response to emergencies. There is no North Slope precedent for a production facility with no infield roads and no fixed-wing access to remote satellite pads. The Alternative E scenario relies solely on helicopters and seasonally-limited off-road vehicles for transportation to East and West pads for most of the year. Moreover, inability to fly in poor weather – up to 10 days at a time – poses unacceptable safety risks, as well as emergency response limitations. Additional helicopter transports would result in long-term noise, which could impact subsistence activities and wildlife. Meanwhile, the infield roads included in Alternative B have been carefully designed and routed to minimize the gravel footprint and to efficiently pass drainage.

Alternative E shortens the airstrip from 5,600 feet to 3,700 feet to minimize the tundra footprint. However, a longer runway provides improved and safer access in bad weather and allows for aircraft with larger cargo capacity. In the event of an emergency, a longer runway would allow for a quicker response in that more equipment could be flown into the area in a shorter period of time.

Compared to Alternative B, a shorter airstrip would triple air traffic during construction and increase annual air flights by 40 percent during operations. Location of the longer runway was carefully designed to minimize impacts to natural runoff during spring breakup and have minimal impact to hydrology.

In our view, a combination of summer coastal barging, winter ice roads, aviation, and infield roads are essential to safe and efficient operations at Point Thomson. ExxonMobil is prepared to implement comprehensive mitigation measures to minimize impact on the tundra, wildlife, aquatic resources, and subsistence activities.

With regard to the nearby Arctic National Wildlife Refuge (ANWR), it is disconcerting that the DEIS places so much emphasis on the proposed project’s proximity to the refuge and implies that the state land beneath Point Thomson should be managed as if they were part of the refuge. RDC joins the State of Alaska in expressing serious concern with the appropriateness of the DEIS assessing such impacts when the project is located on state lands designated for oil and gas development, well outside refuge boundaries. Moreover, a large portion of ANWR already includes over eight million acres designated as Wilderness and ANWR also encompasses vast ecosystems that are specifically designed to protect fish, wildlife, and wilderness values. Therefore, RDC is opposed to extending ANWR’s reach beyond it boundaries.

With regard to polar bears, the Point Thomson project will not pose a threat to the survival of the species. Polar bear denning habitat is plentiful, widely distributed and undisturbed on the Beaufort Sea coastal plain. It is highly unlikely that denning habitat will become a limiting factor for polar bears, even when all foreseeable development activity is taken into account. We certainly do not see any significant impact from Point Thomson on critical habitat for polar bears. Moreover, ExxonMobil works closely with the U.S. Fish and Wildlife Service and state agencies to ensure polar bears and other wildlife are protected. There are extensive measures in place to minimize incidental encounters and protect bears and personnel, as well as surveys and Forward Looking Infrared Radar to identify and avoid dens. There are also project design and operational features to protect bears and humans.

In conclusion, approval of the Point Thomson project as proposed by Alternative B is critical to the development of this world-class resource. The project will provide direct benefits to the State of Alaska and much-needed revenues to local, state and federal governments, as well as boost the private sector economy in Alaska.

Sincerely,
Resource Development Council for Alaska, Inc.