Comment letter to inform DOI’s Review of the Federal Oil and Natural Gas Leasing Program


April 15, 2021

The Honorable Secretary Deb Haaland
U.S. Department of the Interior 
1849 C Street NW

Washington, D.C., 20240

Via [email protected] 

Re: Comments to Inform DOI’s Review of the Federal Oil and Natural Gas Leasing Program

Dear Secretary Haaland: 

The Resource Development Council for Alaska, Inc. (RDC) is writing in help inform the Department of Interior’s (DOI) review of the federal oil and natural gas leasing program, with comments specific to Alaska. 

RDC is a statewide trade association comprised of individuals and companies from Alaska’s fishing, forestry, mining, oil and gas, and tourism industries. RDC’s membership includes Alaska Native corporations, local communities, organized labor, and industry support firms. RDC’s purpose is to encourage a strong, diversified private sector in Alaska and expand the state’s economic base through the responsible development of our natural resources.

RDC believes expanded oil and gas development and production in Alaska will help strengthen American energy independence, advance domestic energy production, and support local job growth. 

Alaska’s economy depends on responsible resource development

Alaska depends on the responsible development of its natural resources to expand and support its economy. Article VIII of our state constitution mandates that Alaska develop its resources to the maximum benefit for all Alaskans.

It wasn’t until the discovery of oil in the 1950s that led Congress to finally vote in favor of Alaska’s statehood. Through the discovery of oil, Congress realized Alaska could have a healthy economy through development of its natural resources. From that, Alaska’s North Slope has produced more than 18 billion barrels of oil since the discovery of the Prudhoe Bay oil field, over 40 years ago. Oil production has been the economic engine of growth in Alaska.

RDC is concerned DOI’s review of the federal oil and natural gas leasing program will impact the ability of its membership to responsibly develop Alaska’s natural resources, including oil and gas. Alaska, and Alaskans alike, depend on the development of natural resources to diversify and support the economy. Further, economic opportunities in rural Alaska are often scarce. The lack of family wage jobs in many regions has resulted in an outmigration of Alaska Natives from the lands their ancestors have lived on for thousands of years.

RDC believes resource development projects in Alaska can be done responsibly, with a strong focus on protecting the environment, including cultural activities and wildlife, providing well-paying jobs, many of which require training and offer a lifetime of opportunity, and improving the long-term economic future for Alaska.

Alaska has rigorous permitting processes

Alaska has rigorous permitting processes that are based on sound science. Alaska utilizes a well-established permitting and review process, with multiple opportunities for public input, and review by local, state, and federal agencies. Billions of barrels of oil have been produced on the North Slope without causing any significant harm to the environment. 

Responsible oil and gas development in Alaska will help ensure America’s energy security for decades and allow Alaska – and America as a whole – to realize the benefits that come from expanding energy production. In addition to the many public services funded across Alaska by revenues derived from oil production, oil exploration, development and production generates thousands of jobs for Alaskans. In rural areas such as the North Slope, the industry and the jobs it provides has generated a stable economy and has improved quality of living, such as increased funding for city and local infrastructure, schools and more. Jobs enable self-sufficiency and provide a means to support a family. This is a major, personal direct benefit of oil and gas development in Alaska.

Technology has led to major advances in reducing industry’s footprint

Decades of oil and gas activity on the North Slope clearly demonstrate industry has the ability to operate throughout the Arctic while maintaining the highest standards of safety and environmental sensitivity. New advances in technology have greatly reduced the footprint of development, allowing for greater consolidation of facilities and the preservation of more acreage within development zones for wildlife habitat. For example, 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.

Alaskans have the greatest stake in seeing that any and all development is done in a way that protects resources, including the environment. RDC believes it can be done, because it’s already being done.

Renewables and alternative energy

RDC acknowledges that there are special interests that oppose further development of fossil fuels in Alaska, the Arctic, and elsewhere. However, oil and gas development in Alaska could ultimately prove indispensable as forecasts indicate America’s energy demands will increase over ten percent in the next quarter century. Despite sharp increases in alternative energy sources, the majority of these growing energy demands will continue to be satisfied through the use of fossil fuels. As long as there is a market for oil and gas, the resources should be developed and produced domestically where operations and emissions are strictly regulated, and best management activities are employed to minimize and avoid impacts.

Opponents of resource development advocate leaving resources in the ground, but even in an era of climate change, reality requires continued development of America’s natural resources, including oil and gas. While renewable and alternative energy will make up a growing part of the U.S. portfolio, they will not significantly reduce our reliance on traditional sources in the near or mid-term.

RDC doesn’t deny renewable energy is a growing part of America’s energy portfolio, but it is still only projected to account for a minority of American energy production in 2040. For example, new oil and gas production will be required to power America’s economy, along with other energy sources, and can serve as a bridge until renewable energy becomes a dominant energy source decades into the future. 

Further, Alaska’s offshore waters and onshore prospects hold the potential to fuel the state’s economy for decades and to play a key role in ensuring America has the energy it needs until alternative sources become economically feasible on a large scale.


In conclusion, RDC appreciates DOI’s consideration of our comments. RDC strongly encourages further engagement between DOI and Alaska’s oil and gas industry, and its communities, to ensure that any changes to DOI’s oil and gas programs and policies do not have unintended consequences and can ultimately be implemented in a cooperative and efficient manner. 

Growth in exploration and development in Alaska would create jobs, stimulate the economy, reduce America’s dependence on foreign oil, and generate much-needed ongoing revenues to the Alaska and federal governments. Moreover, responsible energy development on the North Slope can and does coexist with the environment, wildlife, and subsistence needs of local residents.