August 31, 2017

Ms. Karen Mouritsen, Acting Director
BLM Alaska State Office
222 W. 7th Avenue, Mailstop 13
Anchorage, AK 99513-7504

Re: Call for comments for National Petroleum Reserve – Alaska

Dear Ms. Mouritsen:

Thank you for the opportunity to submit comments at this early stage of the new planning efforts to re-examine future management of the National Petroleum Reserve-Alaska (NPR-A).  Given the outstanding track record of the oil and gas and mining industries in the Alaska Arctic, as well as the technological advances of the past 40 years, the Resource Development Council for Alaska, Inc. (RDC) supports opening all of the energy reserve to oil and gas, mineral, and coal leasing. In addition, RDC encourages the Bureau of Land Management (BLM) to update provisions for transportation corridors inside NPR-A to facilitate future resource development.

RDC is an Alaskan business association comprised of individuals and companies from Alaska’s oil and gas, mining, forest products, tourism and fisheries 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.

Oil and Gas Leasing and Development

Expanded oil and gas development and production in Alaska will help strengthen American energy independence, promote domestic energy production, and support local job growth. However, the 2013 Integrated Activity Plan for NPR-A unnecessarily prohibits leasing and development in much of Northeast NPR-A and oil-rich lands adjacent to Teshekpuk Lake.

In 1923, Congress designated NPR-A for energy production. Therefore, all prospective areas should be opened to leasing, especially closed areas in the northeast part of the energy reserve and lands around Teshekpuk Lake. In planning for future development, BLM can deploy reasonable mitigation measures to protect surface resources important to local residents for subsistence needs, and the environment.

Decades of oil, gas, and mining activity clearly demonstrate industry has the capability 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. 

Industry has proven it can explore and develop potential reserves in these areas in a way that minimizes impacts on the environment, wildlife, traditional subsistence activities, and cultural resources. Industry has taken the best practices and technology of the past 40 years of Arctic development and has applied them to the latest generation of oil field development. This has led to a new and higher standard for environmentally-responsible development and has reduced the footprint of development in sensitive areas.

The discovery and development of new oil and gas deposits will benefit Alaska and local communities. State and local revenues derived from production will help sustain important state services. New industry activity will also provide thousands of job opportunities, boost the local, state, and national economy, and refill the Trans-Alaska Pipeline System (TAPS), which is currently running at three-quarters empty. Development of new energy deposits will also reduce reliance on imported oil and help establish American energy dominance.

Given NPR-A was specifically designated by Congress for the production of energy resources, it is important BLM provide access to prospects with the highest potential. North Slope oil and gas deposits have occurred almost exclusively within a 25-mile strip of the Beaufort Sea coastline – a geologic structure known as the Barrow Arch. Acreage within this area could hold significant deposits and should be open to development.

Three large discoveries have been announced in recent years outside the east and north borders of NPR-A in two little-explored reservoirs that extend into the energy reserve – the Nanushuk and Torok formations. Armstrong Energy and Repsol drilled into the Nanushuk formation in 2015 to make a major discovery in the Pikka Unit, a chunk of State of Alaska leases north of the village of Nuiqsuit. Two wells drilled this winter by Armstrong at a prospect known as Horseshoe showed new evidence of a large find that extends its already huge Nanushuk play by an additional 20 miles.  The Horseshoe wells confirm the Nanushuk reservoir as a significant emerging opportunity on the North Slope and a potential game changer with billions of barrels of conventional oil. Geologists believe the discoveries in the relatively shallow reservoir increase the likelihood of large oil discoveries in NPR-A.

In addition, ConocoPhillips announced in January a major discovery of 300 million barrels of oil at its Willow prospect in Northeastern NPR-A and Caelus Energy Alaska has reported a potential multi-billion barrel field at Smith Bay, located in state waters off the northern coast of the energy reserve. More than 500,000 barrels a day in new production could come from these and other projects on state and federal lands in the area, triggering a major reversal in TAPS throughput.

These new discoveries and the highly-promising Nanushuk reservoir indicate NPR-A’s energy reserves may be much higher than estimated under the Obama administration. Previously, federal geologists estimated the energy reserve contained approximately 10 billion barrels of recoverable oil, but those estimates were sharply reduced to less than 900 million barrels by the Obama administration in 2010. Following that dramatic revision, nearly half of the reserve was put off-limits to development, including large swaths of highly-prospective lands within the Barrow Arch.

RDC is concerned with the alarming trend over the past eight years of “locking up” oil-rich lands in NPR-A and the Alaska Arctic Outer Continental Shelf. Through the previous planning process, 11 million acres of the energy reserve’s 22.8 million acres were closed to leasing, including areas beneath and around Teshekpuk Lake. We are very much concerned that the trend clearly has been toward less leasing and less access. Much of the most prospective acreage within the Barrow Arch has now been removed from leasing, including those closest to potential future production. It is important to remember this is a petroleum reserve.

RDC strongly supports the BLM in re-visiting the Integrated Activity Plan for NPR-A to incorporate the most current information and develop new management goals, objectives, and actions that would be consistent across the entire energy reserve. It is our hope that such efforts will re-open oil-rich areas in the northern areas of the reserve.

RDC recognizes coastal areas of the petroleum reserve contain large populations of waterfowl and caribou and are valued by local residents for subsistence hunting. However, a variety of protective measures, operating procedures, standards, and stipulations are employed to mitigate impacts of energy development on other land uses and resources in areas where development currently occurs on the North Slope. We urge BLM to provide access to NPR-A’s prospective acreage while providing reasonable measures to mitigate impacts. These measures should be both technically and economically feasible.

RDC believes it is unnecessary for BLM to defer or continue to keep closed highly prospective acreage in NPR-A to potential future lease sales. These withdrawals only serve to significantly reduce ultimate recovery of oil from the energy reserve with little or no benefit to the environment and wildlife. If BLM removes the best prospects from future leasing, there is unlikely to be significant industry interest going forward in the energy reserve. If much of the coastal areas remain closed to leasing and exploration, then much of the energy reserve’s potential will be gutted and industry’s interest and investment will move elsewhere beyond Alaska, weakening the local and statewide economy.

Ironically, had sensitive wildlife and wetland areas along the central North Slope coastal plain been withdrawn from exploration in the 1960s, there would have been no discovery of oil at Prudhoe Bay, Kuparuk, and other North Slope oil fields. Alaska would not have the economy and public infrastructure it has in place today, and the nation would have been forced to import at least an additional 17 billion barrels of oil over the past 40 years at a staggering cost. Instead, North Slope oil fields have elevated Alaska’s economy over the past four decades. In addition, the Central Arctic caribou herd population has grown from 5,000 animals in 1970 to over 60,000 in recent years, demonstrating oil and gas development can coexist with wildlife and the environment.

As the BLM begins the process of re-visiting and updating the management plan for NPR-A, we encourage the agency to ultimately produce a plan that demonstrates federal lands in Alaska are open for business.

Minerals and coal leasing

Given the outstanding track record of the mining industry in the Arctic and sub-Arctic, the technological advances of the past four decades, and the increasing need for strategic minerals, RDC also supports opening NPR-A to mineral entry, as well as mineral and coal leasing. RDC acknowledges that before the mining of minerals and coal can occur, an act of Congress would be required to open NPR-A to mineral entry. We encourage the Secretary of the Interior to advance such a recommendation to President Trump.

Specifically, the northern foothills of the Brooks Range have significant potential for base metals discoveries similar to the rich zinc and lead ores found elsewhere in Alaska. It is well known that the region also holds significant deposits of copper and iron, as well as some of the most significant coal deposits anywhere in the world. In fact, America is called the “Saudi Arabia of coal,” partly because of the reserve base inside NPR-A.

NPR-A should be managed with a true multiple use philosophy as mandated by BLM, allowing for the coexistence of development, recreation and subsistence uses. RDC opposes the establishment of single-purpose, highly-restrictive conservation units in NPR-A as Alaska already has an overwhelming majority of the nation’s public lands closed to development. As noted earlier, environmental concerns and habitat issues can be adequately addressed through lease stipulations and the permitting process. Decades of mining activity with today’s technology clearly demonstrate industry has the capability to operate throughout Alaska while maintaining the highest standards of safety and environmental sensitivity.


The development of new oil, gas, mineral, and coal deposits in NPR-A will benefit Alaska, local communities and the nation. Revenues derived from new production will help sustain important state services. Industry activity will also provide new job opportunities for local residents and others while boosting the economy. Increased access to NPR-A should be accommodated with provisions to protect the traditional ways of life, especially the subsistence needs of Northwest Alaska residents.

Opening highly-prospective areas of NPR-A to future lease sales would advance the President’s and the Department of Interior’s “all-of-the-above” approach to energy development, which includes oil and gas, coal, strategic minerals and renewable sources.

Thank you for the opportunity to provide comments in this early planning stage for future lease sales in NPR-A.

Resource Development Council for Alaska, Inc.