Resource Development Council

RDC Comment Letter:
Support of HJR 11 - Oppose New Wilderness Designations in ANWR

February 2, 2011

Representative Eric Feige and Representative Paul Seaton, Co-Chairmen
House Resources Committee
Alaska State Legislature
State Capitol
Juneau, AK 99801

Re: HJR 11, Urging the U.S. Congress to oppose new Wilderness designations on the Coastal Plain of ANWR

Dear Representative Feige and Representative Seaton:

The Resource Development Council for Alaska (RDC) is writing to support HJR 11, which opposes new Wilderness designations in the Arctic National Wildlife Refuge (ANWR).

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.

RDC is not only strongly opposed to the expansion of Wilderness areas in ANWR, we support opening the “1002 area” of ANWR’s coastal plain to oil and gas development. At a minimum, the option of future energy development in the 1002 area should be kept open, considering national economic and energy security imperatives. However, a Wilderness designation over the 1002 area would forever close what is considered America’s best onshore prospect for major oil and gas discoveries.

RDC is advocating for the State of Alaska’s and, indeed, our nation’s interests in recommending the 1002 area be opened to responsible oil and gas exploration and development, as was recommended by the Department of Interior and Congress in the 1980s and 1990s. RDC is strongly opposed to new federal Wilderness designations in ANWR and the mere implication of such consideration is inconsistent with promises that were made in the Alaska National Interest Lands Conservation Act (ANILCA).

The 1002 area was excluded from the Wilderness designation in a compromise struck under ANILCA over 30 years ago. In exchange, Congress doubled the size of the refuge and designated eight million acres outside the 1002 area as Wilderness. In recognizing the 1002 area’s enormous oil and gas potential, Congress mandated a study of the 1002 area’s petroleum resources, as well as its wildlife and environmental values. In 1987, the Department of the Interior recommended the 1002 area be opened “to an orderly oil and gas leasing program.” A 1987 Environmental Impact Statement (EIS) noted in its summary that impacts from “exploration and development drilling were minor or negligible on all wildlife resources on the 1002 area” and that production would directly “affect only 0.8 percent of the 1002 area.” In 1995, Congress voted to open the area to responsible oil and gas development, but President Bill Clinton vetoed the bill. ANILCA Section 1001(e) specifically limited the study period for Wilderness considerations in ANWR’s coastal plain to eight years from the date of signing the act. The 1987 EIS addressed the issue and rejected Alternative E, Wilderness designation of the 1002 area. The EIS pointed out that “such a designation is not necessary to protect the 1002 area environment and is not in the best interest of the nation.”

Moreover, Section 101 states that the need for future Conservation System Units (CSUs) in Alaska has been obviated by the ANILCA withdrawals (105 million acres statewide) and Section 102(4) includes Wilderness in the definition of a CSU. In addition, Congress recognized that for Alaska to “satisfy the economic and social needs of the State of Alaska and its people” access is essential.

Alaska already contains 58 million acres of federal Wilderness. This is larger than New York, New Jersey, Connecticut, Rhode Island, Massachusetts, Vermont and New Hampshire combined. In fact, Alaska accounts for 53 percent of America’s federal Wilderness areas. We don’t need more Wilderness in Alaska, we are already sufficiently protected. This point is acknowledged in Section 1326(a), which states that administrative closures, including the Antiquities Act, of more than 5,000 acres cannot be used in Alaska. Section 1326(b) adds emphasis to the “No More” clause in noting that federal agencies must first seek the permission of Congress before even studying lands in Alaska for Wilderness consideration.

In conclusion, the 1002 area of ANWR should not only continue to be excluded from Wilderness designation, it should be opened up to responsible onshore oil and gas exploration and development. Our national security and Alaska’s economy depend on it. Moreover, we can have oil and gas development in a very small area of ANWR while maintaining the special values of the refuge. Given the majority of Alaskans support oil and gas development in ANWR and are opposed to a Wilderness designation over the 1002 area, RDC strongly encourages the passage of HJR 11.

Resource Development Council for Alaska, Inc.