Resource Development Council

RDC Comment Letter:
Greater Moose's Tooth Draft SEIS Comments

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April 17, 2014

Ms. Bridget Psarianos
U.S. Bureau of Land Management
222 West 7th Avenue, Stop #13
Anchorage, AK 99513

Re: GMT-1 Draft SEIS Comments

Dear Ms. Psarianos:

The Resource Development Council (RDC) is writing in support of Alternative A in the Draft Supplemental Environmental Impact Statement (DEIS) for the Greater Mooses Tooth Unit 1 (GMT-1) Oil and Gas Development Project in the National Petroleum Reserve-Alaska (NPR-A).

RDC is a statewide, non-profit, business association comprised of individuals and companies from Alaska’s oil and gas, mining, timber, tourism and fisheries industries. Our membership also includes Native regional and village corporations, local governments, organized labor and industry support firms. RDC’s mission is to help grow Alaska’s economy through the responsible development of natural resources.

The GMT-1 project is not new. It was reviewed and approved by the BLM and its cooperating agencies in 2004. It was further reviewed in the NPR-A Integrated Activity Plan (IAP). These reviews provided the public with many opportunities to comment and evaluate cumulative impacts. Moreover, the project has been modified only slightly from its original proposal. The project is essentially the same as that approved for permitting in the 2004 Record of Decision and evaluated under the 2012 IAP, with changes that reduced impacts and the overall footprint. We view requests for additional extension of the comment period as delay tactics rather than legitimate concerns for public comment.

RDC, along with our North Slope members, including the North Slope Borough and Arctic Slope Regional Corporation, understand the tremendous benefits of the GMT-1 project to local residents, the state, and the nation. Through the 7(i) provisions of the Alaska Native Claims Settlement Act (ANCSA), this project will provide significant revenues to Alaska Natives throughout the state through royalties and revenue sharing among Alaska Native regional corporations. New oil production from GMT-1 will help offset declining North Slope production. It will create new jobs, generate needed revenues to the borough, state, and federal government, while reducing America’s dependence on imported oil.

As proposed in Alternative A, GMT-­-1 includes a gravel road connection to the main Alpine facilities. The road is necessary to ensure that the operator can quickly and efficiently respond to any environmental and safety issues. Alternative D, the aircraft and ice road access alternative, would not allow adequate access to emergency response resources and creates significant environmental and safety risk. In fact, on bad weather days, there would be no access.

ConocoPhillips’ proposed project, Alternative A, has been modified to reduce environmental impacts and lower the overall footprint. In support of subsistence resources and access, the proposed project drill site location was moved out of the Fish Creek buffer to provide additional protection to this area. Road access will avoid the need for air traffic to the drill site, which is the number one complaint of subsistence hunters. Additionally, the project will be subject to various lease stipulations and the new Best Management Practices adopted by the Bureau of Land Management in 2013.

The overall gravel footprint of Alternative A is the smallest of all the options. Alternative D has a larger gravel footprint than Alternative A because of the need to construct an airstrip and a larger gravel pad to accommodate more production equipment and a camp. In addition, Alternative A has the lowest estimated emissions because it requires the least amount of new infrastructure and eliminates the need for airplane support.

In conclusion, RDC supports Alternative A and encourages BLM to move forward with this project. We have full confidence in ConocoPhillips’ ability to develop GMT-1 in a responsible and safe manner. Thank you for the opportunity to testify on the Draft SEIS.

Resource Development Council for Alaska, Inc.