August 22, 2012
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 Section 404 Permit
Dear Mr. Baij:
The Resource Development Council (RDC) is writing to urge the U.S. Army Corps of Engineers to 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 the winter of 2015-2016.
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.
Permit issuance by the Corps by mid-October is vital to allow construction to begin this winter. If this timeline is missed, then first production will be delayed by at least one more year and over 1,000 potential construction jobs this winter could be lost. ExxonMobil has committed to the State of Alaska to initiate production by the winter of 2015-16. The company would need to begin construction this winter to meet its commitment with the State.
The proposed project provides the safest, most environmentally-sound approach to developing Point Thomson’s resources in a timely and economic manner. The proposed design includes significant mitigation measures to minimize impacts to high-value wetlands, habitat, and hydrology, as well as tundra, wildlife, aquatic resources, and subsistence activities.
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 Trans-Alaska Pipeline System, which is currently operating at less than one-third capacity. In addition, this multi-billion dollar project would provide 1,000 new jobs as early as this winter, 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.
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 as noted above to minimize impacts. The coastal barge route is located inside barrier islands and away from the main fall migration corridor for bowhead whales.
With regard to polar bears, the Point Thomson project will not pose a threat to the survival of the species. The proposed project includes robust marine mammal and wildlife protection plans recognized by the U.S. Fish and Wildlife Service as North Slope industry best practices. Project design and operational features will be implemented to protect bears and humans.
Moreover, 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.
In conclusion, RDC strongly urges the Corps to approve the Point Thomson project as proposed and to issue the Section 404 permit no later than mid-October so the project can move forward immediately.
Resource Development Council for Alaska, Inc.