June 7, 2010
US Fish & Wildlife Service
Arctic NWR - Ms. Sharon Seim
101 12th Avenue, Room 236
Fairbanks, AK 99701-6237
Dear Ms. Seim:
The Resource Development Council for Alaska (RDC) appreciates the opportunity to provide comments to the U.S. Fish and Wildlife Service (USFWS) on the upcoming revision to the Comprehensive Conservation Plan (CCP) for the Arctic National Wildlife Refuge (ANWR). Given the USFWS is seeking public comments on the refuge and its future uses and management, RDC would like to take this opportunity to encourage the agency to open 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.
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 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 80s and 90s. 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).
We strongly support the Obama administration’s goal to decrease dependence on oil by sharply increasing renewable energy production. However, even with this emphasis on renewable growth, it is still projected that fossil fuels will account for over 65% of this nation’s energy consumption in 2025. In fact, according to the Energy Information Administration (EIA), in 15 years demand for oil will increase by 39 percent and demand for natural gas by 34 percent. Where will the oil come from?
Over the past 36 years, all U.S. Presidents have pledged to reduce America’s reliance on foreign oil, beginning with President Nixon in 1974, when the nation imported 36 percent of its oil from abroad. Our dependency on foreign oil has steadily increased, reaching 66.2 percent in 2009 when President Obama said, “It will be the policy of my administration to reverse our dependency on foreign oil while building a new energy economy that will create millions of jobs.”
According to a May 2008 EIA report, ANWR oil and gas development could result in new domestic production ranging from 510,000 to 1.45 million barrels per day for a period extending for approximately 12 years, with additional production for many years following. Such production would save the nation billions of dollars in imported oil while creating thousands of new jobs and generating billions of dollars in new revenues to the federal and Alaska treasuries.
Without new production from places like the 1002 area or the Outer Continental Shelf (OCS), we are setting ourselves up for increasing reliance on importing oil from OPEC nations to meet our demand. It’s time we bring these opportunities to American soil where environmental oversight and protection are second to none, and the 1002 area is the most prospective onshore prospect in our country with an estimated 5.7 to 16 billion barrels of technically recoverable oil.
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.
Now new Wilderness designations are being considered. A federal Wilderness designation over the 1002 area would forever place off-limits North America’s most prolific onshore oil and gas prospect and would mean abandoning the 1980 compromise. This is unacceptable.
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.
What we need in Alaska is more economic opportunities, and if the 1002 area is opened, not one acre of designated Wilderness would be disturbed by oil and gas development. With advances in technology significantly diminishing the footprint of development, we do not have to choose between energy production and environmental protection. It is possible to develop the 1002 area’s energy reserves while directly utilizing only a fraction of the area. This can be accomplished without significant disturbance to wildlife. In fact, wildlife populations have grown or remained stable in other areas of the North Slope where oil development is already occurring. One example at Prudhoe Bay shows the central arctic caribou population has grown from 5,000 animals in 1970 to more then 66,000 animals today. Development and protection of the environment do co-exist in Alaska and this environmental ethic will continue to be a priority.
America has the ability to develop the vast energy resources beneath the 1002 area in a responsible manner while the federal government manages surface lands to preserve habitat and wildlife. The USWFS can continue to sustain fish and wildlife species, provide opportunities for recreation and wilderness solitude, facilitate subsistence activities, and honor international treaty obligations in ANWR without designating the coastal plain Wilderness.
Oil and gas operations coexist with wildlife and the environment in many refuges across this nation. Of 500 refuges, wetlands management districts, and other lands administered by the USFWS, oil and gas activities occur or have occurred on 155 of these units. These refuges include the Aransas Pass National Wildlife Refuge that provides the winter range for the endangered whooping crane, and the Kenai National Wildlife Refuge in Southcentral Alaska, where the Swanson River oil field provided the catalyst for Alaska statehood in 1959. Clearly, the USFWS has the management experience to manage wildlife conservation and protection of the environment with the responsible development of energy resources the nation so desperately needs. The agency can strike a balance which accomplishes both.
Alaskans strongly support oil exploration in the 1002 area. In fact, a recent poll revealed 78 percent of Alaskans statewide support exploration and development in the 1002 area of ANWR. Every Alaskan governor and every standing legislature and elected congressional representative and senator from Alaska have supported responsible development. The North Slope Borough, the regional government for the entire Alaskan Arctic, also supports responsible development, as well as a majority of residents in Kaktovik, the only village within the coastal plain.
The economic and energy security benefits of ANWR oil and gas production are enormous and must be weighed against any Wilderness designation. Oil development in the 1002 area would:
- Substantially boost domestic production and provide a safe and secure source of oil to the nation for decades;
- Reduce both foreign oil imports and the national trade deficit, saving America hundreds of billions of dollars annually;
- Generate between $152-237 billion dollars in royalty and tax revenues for both the federal government and the State of Alaska, according to the Office of Management and Budget;
- Create between 250,000 and 735,000 jobs throughout the country;
- Reverse declining oil production on the North Slope and refill the Alaska oil pipeline, which is currently operating at only one-third of its original capacity, and
- Enhance the long-term economic viability of the proposed Alaska gas pipeline to the Lower 48, given the 1002 area could contain 18 trillion cubic feet of natural gas, and additional gas reserves beyond what has already been discovered on the North Slope are needed to make the project economic.
Revenue projections to the federal government and the State of Alaska do not include potentially large revenues from the production of natural gas, which likely exist in large quantities in the 1002 area. With up to 16 billion barrels of oil beneath the 1002 area, responsible oil and gas production is clearly in the best interest of the nation and Alaska. Moreover, there is no denying the fact that the nation needs the substantial energy resources beneath the 1002 area until America fully transitions to renewable and alternative energy sources decades from now.
Yet despite ANWR’s potential and the fact that it is the nation’s most prolific onshore oil and gas prospect, the U.S. is choosing to import nearly 70 percent of the oil it consumes – at a great cost. Not developing its reserves in Alaska makes no sense from an economic and energy security stand point. American oil production is projected to decrease by 9.9 billion barrels within the next 20 years, nearly a 15 percent annual decrease from current levels. Meanwhile, imports of oil from OPEC are projected to increase by 4.1 billion barrels, nearly 19 percent – and at a cost of $607 billion. Developing ANWR’s energy resources would not meet all of our needs, but combined with conservation, alternative fuels and other energy initiatives, it would be a significant step in curbing imports. Meanwhile, the cost of not developing additional U.S. reserves would put a huge burden on the national economy.
In Alaska, oil production from the 1002 area would sustain Alaska’s economy for decades. Yet without access to new significant oil deposits, the Alaska oil pipeline could be forced to shut down prematurely, resulting in the loss of 90 percent of the State of Alaska’s revenue base and severely damaging the very foundation of its economy. Currently, there are more than 108,000 Alaskan jobs tied to the discovery, production and shipment of Alaskan oil and natural gas, accounting for more than 15 percent of Alaska’s population. Moreover, two-thirds of all State of Alaska government jobs are funded by revenues generated from oil production. Energy exploration in the 1002 area would not only sustain these jobs in both the public and private sectors, many more would be created in the private sector in Alaska and elsewhere. All of these positive economic and energy security benefits must be acknowledged in the CCP.
Given recent events in the Gulf of Mexico, opponents of offshore oil and gas development are calling for an end to new exploration and development pretty much everywhere. They are seizing on this national tragedy to rally against possible future development, not just offshore in the OCS, but onshore in the 1002 area of ANWR, despite the fact there are significantly different characteristics between onshore and offshore development. In our view, the Gulf oil spill strengthens the case for onshore exploration and development in ANWR. Producing oil and gas from onshore or from shallow Arctic waters offshore poses much lower risks than from deep water areas in the Gulf of Mexico. The tragedy in the Gulf reminds us that there is always some risk of developing our energy resources, but we cannot simply ignore our need for oil and gas. If we don’t drill where there are significant deposits of oil and gas, such as the OCS or ANWR, to help meet our future energy needs, where will we drill?
In conclusion, If the 1002 area is designated Wilderness, the nation will be forced to import billions of barrels of additional oil. Every barrel of oil not developed domestically is a barrel of oil imported from abroad, some of which come from unfriendly countries and under weaker environmental standards than those enforced in America. 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. At the very least, the USFWS should avoid any administrative action that would place the vast energy resources of the 1002 area permanently off-limits to development.
Thank you for the opportunity to comment on the ANWR CCP.
Resource Development Council for Alaska, Inc.