Action Alert: Call for comments for National Petroleum Reserve-Alaska
Comment deadline was January 22, 2019

View RDC comments here


The U.S. Department of the Interior’s Bureau of Land Management (BLM) is seeking public comments to help guide the development of a new Integrated Activity Plan (IAP) and associated Environmental Impact Statement (EIS) for the 22.1 million-acre National Petroleum Reserve-Alaska (NPR-A). 

The purpose of the IAP/EIS is to develop a new management strategy for NPR-A consistent with Secretarial Order 3352, which was signed in June 2017.  The order calls for the review and development of a revised IAP “that strikes an appropriate balance of promoting development while protecting surface resources.” 

The request for comments over the entire NPR-A is the first step in revising the previous management plan, which closed 11 million acres of the energy reserve to leasing, including 3.1 million acres of highly-prospective lands contiguous to recently announced discoveries.  

The new IAP/EIS will include a range of alternatives that make lands available for leasing, an examination of special area boundaries, and a consideration of new or revised lease stipulations and best management practices. The IAP/EIS would also ensure that BLM’s land management plan will provide an opportunity, subject to conditions developed through a National Environmental Policy Act process, to construct pipelines and other necessary infrastructure to bring oil and gas resources from offshore or adjacent leases to the Trans-Alaska Pipeline Systems (TAPS). It would also consider the potential for a road system to connect communities across the western North Slope.

Action Requested:

Please submit comments encouraging BLM to reopen all of NPR-A’s subsurface historically opened to oil and gas leasing, including transport of energy resources. 

Mail comments to: State Director, Bureau of Land Management, Alaska State Office, 222 West 7thAvenue, Mailstop 13, Anchorage, AK 99513. Comments may also be faxed to (907) 271-5479 or submitted online at

Points to consider in your comments:

  • The 3.1 million acres of subsurface in Northeast NPR-A that has historically been open to oil and gas development should be available for leasing, with mitigation measures to protect surface resources and subsistence but which also allow development of energy deposits and infrastructure necessary to transport onshore and offshore energy resources to TAPS. 
  • The current land management plan for NPR-A is inconsistent with the primary purpose of the petroleum reserve and unnecessarily emphasizes preservation over multiple use. 
  • The 2013 Integrated Activity Plan unnecessarily prohibits leasing and development of potentially oil-rich lands in much of Northeast NPR-A south of Teshekpuk Lake. The 3.1 million acres that were taken off the table in Northeast NPR-A was an overreach. Oil and gas leasing and exploration drilling has occurred on these lands in the past and should be allowed.  It is important to remember this is a petroleum reserve and surface resources and subsistence can be protected without closing all areas to leasing. 
  • Advances in technology have greatly reduced the footprint of development in the Arctic. As much as 60-plus square miles can now be developed from a single 12 to 14 acre gravel drillsite. New drilling capabilities are being developed that may increase the subsurface development possible from the same size drill site to as much as 150-plus square miles. The net effect is an ever-decreasing impact on surface resources. 
  • Experience supports the fact that development of oil and gas resources can coexist with traditional subsistence activities, cultural resources, wildlife, and the environment. 
  • Geologists believe that recent large oil discoveries in the Nanushuk formation found in the area west of the Kuparuk River Unit and the eastern portion of NPR-A that is available for leasing indicate potential large oil deposits in the energy reserve.
  • The discovery and development of new oil and gas deposits will benefit local communities, Alaska, and the nation. State and local revenues derived from production will help sustain important state services to residents and diminish dependence on foreign oil.
  • New industry activity could provide thousands of job opportunities, boost the local, state and national economies, and add new oil to TAPS, which is currently running at three-quarters empty. 
  • The IAP should allow for a year-round road system to connect local communities within NPR-A.
  • Opening highly-prospective areas of NPR-A to future oil and gas lease sales while still protecting the most sensitive areas would advance BLM’s “all-of-the-above” approach to energy development and help establish American energy dominance. 

Deadline Tuesday, January 22, 2019