RDC Comment Letter

Overview
The Bureau of Land Management (BLM) has announced a Supplemental Environmental Impact Statement (SEIS) on the oil and gas lease sales in the 1002 Area of the coastal plain of the Arctic National Wildlife Refuge (ANWR). Public comments on the SEIS are due October 4th. 

An earlier Final EIS found that oil and gas development in the 1002 area of ANWR, an area set aside for oil and gas exploration, can take place without harming the environment. Alaska is America’s energy warehouse, and we can develop the resources in ANWR while protecting the refuge. The Notice of Intent to prepare a SEIS states the SEIS will include alternatives that “[d]esignate certain areas of the Coastal Plain as open or closed to leasing.” Such alternatives are beyond the Secretary of the Interior’s statutory authority.

Neither Alaska National Interest Lands Conservation Act (ANICLA) nor the Tax Cuts and Jobs Act (Tax Act) grant the Secretary of the Interior the authority to temporarily or permanently “withdraw” any portion of the Section 1002 Area from oil and gas leasing or development. ANILCA specifically identified the Section 1002 Area as a potential area for oil and gas leasing as part of the agreement struck among the State of Alaska, the federal government, and native groups to allocate land within the State. Congress made the final determination in the Tax Act to open the Section 1002 Area for leasing and specified a precise timeframe for the Department to hold lease sales. The prior Administration complied with the law by holding a lease sale before the first required deadline of January 2021. Neither ANILCA nor the Tax Act includes any mechanism or grant of authority for the Secretary of the Interior to withdraw some or all of the Section 1002 Area from leasing.

The footprint of production and support facilities will be limited to no more than 2,000 surface acres at any given time, including private land holdings inside the coastal plain. Future on-the-ground actions, including potential exploration and development proposals, will require further National Environmental Policy Act analysis based on the site-specific proposal. As a result, decisions evaluated in the initial EIS and its record of decision would not authorize any on-the-ground activity associated with the exploration or development of oil and gas resources on the coastal plain. 

In 1980, Congress identified the 1002 Area for its potential oil and gas resources. A 1987 Department of the Interior report fulfilling requirements under Alaska National Interest Lands Conservation Act (ANILCA) recommended the 1002 Area for oil and gas development. Since completion of that report, numerous oil fields have been discovered near the coastal plain and oil field technologies have significantly evolved to greatly diminish the footprint of development.

Action Requested:

RDC members are encouraged to comment on the SEIS before the October 4^th deadline.

Website: https://eplanning.blm.gov/eplanning-ui/project/2015144/510

Mail:
Ms. Serena Sweet, Project Lead
BLM Alaska State Office
Attn: Coastal Plain Oil and Gas Leasing Program Supplemental EIS
222 West 7th Avenue, Stop #13
Anchorage, Alaska 99513

Points to consider in your comments:

• BLM’s decision to stall ANWR development is a bad message for investment in Alaska. An EIS was already completed in September 2019 and it determined that oil and gas development could take place without harming the refuge.

• Responsible oil and gas development in the small fraction of ANWR proposed for leasing will help ensure America’s energy security for decades and allow Alaska – and our nation as a whole – to realize the benefits that come from expanding energy production in Alaska.

• The initial EIS included a wide range of alternatives which contain measures to avoid or mitigate surface impacts and minimize ecological disturbance throughout the program area.

• Under the three development alternatives, the footprint of production and support facilities will be limited to no more than 2,000 surface acres of the 1.6 million-acre 1002 Area, which is the non-Wilderness portion of the refuge’s coastal plain. That is equivalent to just 0.01 percent of ANWR’s 19.3 million-acres. 

• Energy production from the non-Wilderness coastal plain has the potential to offset a decline in Lower 48 shale oil production, which is expected to commence in approximately a decade. Without limited oil development on the coastal plain, America will be forced to once again increase its reliance on foreign imports. With limited development in ANWR, America and Alaska can continue to grow the economy and reduce dependence on foreign oil. 

• The program area covered by the initial EIS contains an estimated 7.68 billion barrels of technically recoverable oil and 7 trillion cubic feet of natural gas.

• Alaska’s economic lifeline, the Trans-Alaska Pipeline System (TAPS), is now running at three-quarters empty. New oil production from the coastal plain has the potential to reverse throughput in TAPS, a vital component of American energy infrastructure. 

• Oil development on a fraction of the coastal plain would create thousands of jobs nationwide, generate billions of dollars in government revenue for public services, keep energy prices for American consumers affordable, and further improve energy security for decades into the future.

• Since the non-Wilderness coastal plain is less than 60 miles from TAPS, development of energy resources there is one of the most environmentally-sound ways to increase oil production in Alaska.

• Thanks to continuing improvements in technology, practices, and oversight, the oil industry has demonstrated over the past 40 plus years that North Slope energy development and environmental stewardship can and do coexist. The industry has a proven track record of responsible development in sensitive areas, protecting the environment, wildlife and subsistence needs of local residents. 

• It would be beneficial to continue producing oil on the North Slope, which is one of the cleanest energy sources in the world. Oil and gas that isn’t produced in Alaska’s Arctic will be imported from abroad to supply West Coast refineries. Shifting oil production to nations with lower environmental standards and higher carbon emissions will not benefit America nor reduce climate impacts. 

• 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 drill site. 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.

• Development of Native-owned lands on the non-Wilderness coastal plain would provide significant economic benefits to Alaska Natives on the North Slope as well as throughout the state through direct payment of royalties and revenue sharing among the Alaska Native corporations and their shareholders.

• Polls have consistently shown Alaskans overwhelmingly support responsible oil and gas development in the non-Wilderness portion of ANWR.  There is no valid reason why we should not be allowed to access the world-class resources within just a miniscule fraction of the coastal plain.

• The coastal plain was specifically identified by Congress, pursuant to Section 1002 of ANILCA, for its potential for oil and natural gas resources. Oil and gas from the Non-Wilderness portion of the coastal plain is an important resource for meeting our nation’s energy demands and achieving energy dominance.

Comment Deadline October 4, 2021