Resource Development Council

RDC Comment Letter:
Draft Environmental Assessment for proposed 3-D Seismic Survey

May 23, 2013

Mr. Andy Loranger, Refuge Manager
Kenai National Wildlife Refuge
Box 2139
Soldotna, AK 99669

Re: Draft Environmental Assessment for proposed 3-D Seismic Survey

Dear Mr. Loranger:

The Resource Development Council for Alaska, Inc., (RDC) is writing to support the issuance of a special use permit to Apache Corporation for a three-dimensional (3-D) seismic survey in the Kenai National Wildlife Refuge. The purpose of the survey is to obtain high quality imagery of subsurface geological features, which may contain recoverable oil and natural gas owned by Cook Inlet Region Inc. (CIRI) within the refuge.

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.

Approximately 39 percent of Apache’s leases with CIRI occur within the Kenai refuge. As part of its overall oil and gas exploration program in the Cook Inlet Basin, Apache is proposing to conduct a 3D seismic survey on lands within the refuge to image geologic features in areas of the CIRI-owned mineral estate. These activities will occur on refuge lands overlying CIRI-owned resources and subsurface estate. In addition, Apache will use Tyonek Native Corporation (TNC) lands within the refuge for seismic survey activities associated with imaging off-refuge subsurface resources.

Given tight energy supplies in Southcentral Alaska, the proposed 3D seismic survey could ultimately lead to the development of much needed energy resources for Alaska’s most populous region. The survey is clearly in the public interest as it could give Apache the information it needs to secure a stable source of energy for local communities and utilize a valuable resource for Alaskans.

More than half of the state’s population depends on natural gas from the Cook Inlet region for home heating, electricity and commercial enterprise. Continued development of Alaska’s natural resources is critical to local communities and the state’s economy and the quality of life of our residents.

Development of potential energy resources in the CIRI subsurface will provide new jobs on the Kenai Peninsula and royalties to shareholders of CIRI. Apache’s 2013-14 exploration program itself is estimated at $510 million, with some 380 jobs generated. Operation of Apache’s 2011-12 seismic program resulted in some 225 direct, indirect, and induced jobs resulting in more than $22.5 million a year in payroll. Because of Apache’s local hire policies, 60 percent of these jobs went to Alaska residents.

The Alaska National Interest Lands Conservation Act (ANILCA) requires the U.S. Fish and Wildlife Service (Service) to provide access to the privately-owned mineral resources within the refuge. In addition, the Cook Inlet Land Exchange requires the Service to allow access for exploration and development of the subsurface estate. RDC supports the Service’s acknowledgment and demonstration of its commitment to provide access as outlined in ANLICA and the land exchange.

Access to and the development of CIRI subsurface energy resources would represent a step forward in meeting the economic obligations of the Native people of Alaska as envisioned by the Alaska Native Claims Settlement Act (ANCSA). Revenues CIRI ultimately receives from the development of its subsurface estate will be shared with other Native corporations and their shareholders across the state through Section 7(i) revenue-sharing provisions of ANCSA.

Apache has contractual agreements with CIRI and Tyonek Native Corporation (TNC) to conduct oil and gas exploration and development activities on CIRI and TNC surface and subsurface lands of interest on the Kenai Peninsula. RDC supports the partnership established between CIRI, TNC, and Apache as a demonstration of a successful engagement between Alaska Native corporations and private companies. In passing ANLICA and ANCSA, we believe this type of partnership is what Congress encourages. Likewise, we believe Congress would encourage federal agencies to cooperate with such efforts.

RDC supports the advancement of the wireless modal technology, which has a much smaller impact on the environment than traditional cable seismic technologies. The Environmental Assessment has indicated that under the proposed action, noise, visual resources, and air quality impacts would be minor and temporary. Impacts to soil, vegetation and hydrology would be minimized, given the proposed activity would be completed between October and April while the ground is frozen. No tracked vehicles would be used for this work. All activity for the Apache 3D seismic survey would be supported by helicopters.

RDC supports Apache’s efforts to explore for potential oil and gas resources on the Kenai Peninsula based on Apache’s continued community outreach efforts, economic support, and efforts to work with local, state, and federal agencies on their Cook Inlet program. Moreover, development of potential resources is clearly in the public’s interest, as noted above.

RDC is confident Apache and CIRI will work diligently to insure a successful, environmentally-sound project. We urge the Service to clearly recognize the many benefits of 3D seismic and subsequent development of energy resources to Alaskans and the local economy.

RDC encourages the Service to issue the special use permit in a timely manner.

Resource Development Council for Alaska, Inc.