August 15, 2017

Ms. Kelly Hammerle
National Program Manager
Bureau of Ocean Energy Management
45600 Woodland Road
Mailstop VAM-LD
Sterling, Virginia 20166 

RE: Request for Information on 2019-2024 Outer Continental Shelf Oil & Gas Leasing Program

Dear Ms. Hammerle:

I am writing on behalf of the Resource Development Council for Alaska, Inc. (RDC) to express strong support for a new five-year Outer Continental Shelf (OCS) oil and gas leasing program that would replace the current program which excluded most of the Alaska Arctic from future exploration and 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.

RDC urges the Bureau of Ocean Energy Management (BOEM) to consider in the Draft Proposed Program (DPP) those areas that were not included in the 2017-2022 program, especially prolific areas of the Beaufort and Chukchi seas. By scoping all areas for potential leasing, BOEM would ensure all options remain on the table and the most promising opportunities are seriously considered.

The Beaufort and Chukchi seas form one of the most prospective basins in the world. Together, these areas are estimated to hold 23.6 billion barrels of oil and 104 trillion cubic feet of natural gas. In fact, the Alaska Arctic would constitute the eighth largest oil resource in the world, ahead of Nigeria, Libya, Russia, and Norway.

The Arctic’s untapped resources are of critical importance to both Alaska and the United States. Oil and gas development offshore the North Slope is predicted to produce an annual average of 35,000 direct and indirect jobs over the next half century for Alaska alone. Those jobs would represent a total payroll of over $70 billion.

Economic activity resulting from OCS development in Alaska is estimated to generate an annual average of nearly 55,000 jobs nationwide, with an estimated cumulative payroll amounting to $145 billion over the same time period. From an economic standpoint alone, Arctic OCS development would represent a windfall for the national economy.  Revenues generated from Arctic OCS oil and natural gas production could amount to $200 billion to federal, state and local governments.

In Alaska, offshore development would serve to help maintain the integrity of the Trans-Alaska Pipeline System (TAPS). The pipeline, which came on line 40 years ago, has safely transported more than 17 billion barrels of oil. TAPS reached peak throughput in 1988 at two million barrels a day, at which time accounted for 25 percent of domestic production. However, throughput has now declined to approximately 528,000 barrels per day, despite the vast resources available in the Arctic – both onshore and offshore.  Future offshore production could stem the decline, allowing for TAPS to remain viable for decades. In contrast, excluding the Alaska Arctic from future lease sales could lead to the premature shutdown of TAPS and compromise the long-term energy and economic security of Alaska and the nation.

Industry has shown that impacts to marine mammal subsistence activity can be avoided and mitigated through close cooperation and communication with subsistence users. Newly instituted technologies will further ensure that development and environmental protection can continue to coexist in the Arctic.

Leasing and subsequent exploration and development would bring much-needed infrastructure to the region and would also provide additional response capabilities in an area where shipping and other activities are increasing.

In addition to the Alaska Arctic, BOEM should also consider expanding access in the Gulf of Mexico and provide access to the Atlantic basin to bolster domestic energy production. Such action would generate hundreds of thousands of new jobs, billions of dollars in new federal revenues, and help establish American energy dominance. Currently, 94 percent of the American OCS is unavailable for leasing. Overall, the federal OCS is estimated to contain 89.9 billion barrels of oil and 327.5 trillion cubic feet of natural gas.

However, there are special interests in our nation that are opposed to further development of America’s energy resources – both offshore and onshore. They advocate leaving oil in the ground, but even in an era of climate change, reality requires continued development of America’s oil and gas resources. While renewable and alternative energy will make up a growing part of the U.S. energy portfolio, they will not significantly reduce our reliance on oil in the near or mid-term, given they are projected to account for a relatively small percentage of America’s energy in 2030. The health of our economy and national security will require utilization of both conventional and unconventional energy sources.

Every barrel of oil not developed in America will simply be imported from overseas where environmental regulations are often weaker.  To further reduce our reliance on foreign sources of oil, America must continue to pursue responsible oil and gas development onshore and offshore Alaska, in the Lower 48 states, the Gulf of Mexico, and the Atlantic basin. New production would provide a bridge to the alternative and renewable energy sources of the future.

In conclusion, RDC encourages BOEM in its new five-year program to provide access to those areas of the Arctic that were omitted from the current program. Thank you for the opportunity to submit comments on the new 2019-2024 program.

Resource Development Council for Alaska, Inc.