RDC Comment Letter

Overview                                                                                                                                        

The Bureau of Land Management (BLM) is seeking public input on the Supplement to the Draft Environmental Impact Statement (EIS) for the proposed Willow Master Development Plan (MDP) in the National Petroleum Reserve in Alaska (NPR-A).  

In response to stakeholder concerns and public comments on the Willow Master Development Plan Draft EIS, the applicant submitted an updated project proposal that includes new project components. The updated project proposal was received by BLM in November 2019, shortly after the comment period closed on the Draft EIS. The new proposal includes a third module transfer option, construction of a freshwater reservoir, and up to three boat ramps for subsistence use. While there are minor design optimizations across the project area, the three new project components have not been previously analyzed or shared with the public.

Module Transfer Option 3 would allow for delivery of the heavier modules first to Oliktok Dock, then use existing gravel roads and land-based ice roads for transporting modules to the site of the Willow Central Facility. 

The BLM is releasing the Supplement to the Draft EIS to present the new information and subsequent analysis for a 45-day public comment period. To ensure that comments will be considered, the BLM must receive written comments on the Supplement to the Draft EIS no later than Monday, May 4, 2020.

Action Requested

RDC members are encouraged to testify at an upcoming virtual public hearing and submit comments in support of Alternative B and the module transfer Option 3. You must pre-register to attend a meeting virtually or by phone.

Virtual Public Meeting: Join by registering at 
https://eplanning.blm.gov/epl-front-office/eplanning/planAndProjectSite.do?methodName=dispatchToPatternPage&currentPageId=161460

Join by telephone: Pre-register at 833-517-0203

Thursday, April 16, 2020 — General Public 
1:00 p.m. Registration link: https://zoom.us/webinar/register/WN_v9xUiuiaSJCZP7XBqkznWA 
6:30 p.m. Registration link: https://zoom.us/webinar/register/WN__-PlPJ0KS02CA2V_bf5C0A 

Thursday, April 21, 2020 — North Slope Communities (North Slope residents given priority for registration) 
1:00 p.m. Registration link: https://zoom.us/webinar/register/WN_QF9kM8c-QxmssC71MLvb1Q
6:30 p.m. Registration link: https://zoom.us/webinar/register/WN_8H7AYxnvTBOmse8zySXpew

April 23, 2020 — Nuiqsut (Nuiqsut residents given priority for registration)
1:00 p.m. Registration link: https://zoom.us/webinar/register/WN_F_jAGpuXS96h3KollZAbqg
6:30 p.m. Registration link: https://zoom.us/webinar/register/WN_2gNNYDcORb-SxILxbHRcKA

Wednesday, April 29, 2020 — General Public 
1:00 p.m.  Pre-registration required: https://zoom.us/webinar/register/WN_miqzqMJ0QWu3kHa0NzW_kg
6:30 p.m.  Pre-registration required: https://zoom.us/webinar/register/WN_2tBiFdvYQ628cd60v6EL1g

Comment online: 
https://eplanning.blm.gov/epl-front-office/eplanning/comments/commentSubmission.do?commentPeriodId=8001249

Comment by mail: Willow DEIS Comments, BLM Alaska State Office, 222 W 7th Ave. #13, Anchorage, AK 99513

Points to consider:

• The BLM should adopt Alternative B, as its Preferred Alternative and module transfer Option 3 in the Final EIS.
• Option 3 addresses concerns from North Slope communities about a gravel island’s potential impacts on marine mammal subsistence activities and decreases the amount of gravel needed for the project.
• Option 3 would allow for delivery of the heavier modules first to Oliktok Dock, then use existing gravel roads and land-based ice roads for transporting modules to the site of the Willow Central Facility.
• Alternative B reflects feedback from North Slope stakeholders that the project proponent received and demonstrates its willingness to work with communities to minimize the impact of the project.
• Significant public engagement has occurred to date through public scoping and public comments on the Draft EIS. BLM’s current SDEIS public comment period should not be paused or extended. BLM has found new ways to engage the public on the SDEIS during the COVID-19 pandemic by leveraging new and traditional technologies. There has been ample opportunity for public comment. 
• The BLM deserves recognition for finding new ways to continue to engage the public and progress permitting during the COVID pandemic. BLM is holding eight virtual meetings with Zoom. In addition, there are call-in options using telephones; live streaming options with Facebook groups; hard copies of the SDEIS and the presentation have been mailed to North Slope communities; and the BLM has coordinated with the North Slope radio station KBRW to air the presentation in Inupiat. Comments can still be provided through traditional means such as letters and via email. BLM is making a notable effort to provide opportunities for meaningful comment.
• The State of Alaska, Department of Natural Resources, provided a letter to BLM on April 3^rd, 2020 which states: “This project will bring critical revenue and jobs to the State and the nation during an essential time where both will need to recover from the economic impacts resulting from COVID – 19. If the Willow project stays on its current timeline it will significantly help the State recover from the current fiscal situation and COVID-19 impacts. If BLM’s EIS process experiences future and further delays the State will certainly, and unnecessarily, experience prolonged economic impacts.”
• Development of the proposed $5-$6 billion project would provide benefits to the local and state economies through local hire for jobs created during construction and operations, tax revenues, federal revenue sharing from royalties and lease rentals/bonuses, and new resources to help meet domestic energy demand. 
• The Willow project could create more than 2,000 construction jobs and 300 permanent jobs at a time when Alaskans need jobs. Moreover, the BLM estimates that Willow could generate more than $10 billion dollars in federal, state, and North Slope Borough revenue. 
• The project development plan conforms to BLM’s 2013 Integrated Activity Plan (IAP) which provides a framework for minimizing impacts. The project proponent has collected extensive biological and engineering data since 2017 to inform the Willow EIS process.
• Production from Willow would serve to help maintain the integrity of the Trans-Alaska Pipeline System (TAPS), a critical link to America’s energy distribution. Given the vast resources believed to be available in NPR-A, future production could reverse the decline in TAPS, allowing it to remain viable for decades.
• Conversely, prohibiting development and production at Willow would set a dangerous precedent for future development in NPR-A, severely compromising the long-term energy and economic security of Alaska and the nation.
• Production from Willow would help meet the purpose of NPR-A, which is to develop America’s energy resources. The 23-million acre reserve was set aside nearly a century ago for its petroleum value. In an updated report, the U.S. Geological Survey estimates the reserve could hold nearly 9 billion barrels of oil.
• The industry has made great strides in responsibly designing projects in the Arctic with minimal impact on the environment, wildlife, and subsistence activities.
• Alternative B minimizes impacts and maintains high standards for safety and emergency response and leverages contemporary North Slope best management practices to avoid and minimize impacts.
• Alternative B would reduce environmental impacts compared to other alternatives by using less gravel fill, fresh water, and aircraft flights, while improving year-round access for local residents.
• The industry employs rigorous standards to protect the environment and subsistence resources. Industry has an excellent track record and a long history of operating responsibly and working with stakeholders on the North Slope and in the Arctic.
• Industry and the State have made great strides in designing responsible development plans in the Arctic with minimal impact on the environment, wildlife, subsistence harvest activities, and cultural traditions.
• Since 2017, the applicant has collected extensive avian, fish, hydrology, vegetation, and cultural resources data in the proposed Willow area.  In addition, the applicant has been surveying caribou movements in the Willow area for nearly 20 years.  All of this scientific data has been used by BLM and the other cooperating agencies to assess impacts which are discussed in detail in the DEIS and SDEIS.  The scientific reports, collected and reported by third-party scientific firms, are available on the North Slope Science Initiative website.
• Extensive mitigation and engineering design features are incorporated into the Willow project.  For instance, pipelines will be elevated to at least 7 feet and separated from roads to allow for caribou movements.  Engineering features like this are incorporated throughout the project – we’ve learned a lot since Prudhoe Bay was first developed and minimizing environmental impact is a core driver in our oilfield design.

 Comment deadline is May 4, 2020