RDC Comment Letter 

Good evening. My name is Leila Kimbrell, Executive Director of the Resource Development Council for Alaska, Inc. (or “RDC”). RDC is an Alaskan trade association with members in fishing, forestry, mining, oil and gas, and tourism, including Alaska Native corporations. 

RDC supports the proposed Supplemental EIS for the Willow Project and encourages BLM to adopt Alternative E without further delay. The multi-year environmental analysis conducted for this project has been extensive and shows that Willow can be developed responsibly in accordance with our laws and environmental protections. 

RDC previously supported Alternative B that was selected by the Final EIS issued in 2020 for this project, which was the culmination of extensive effort and scientific analysis by BLM and together with multiple state, federal, and local cooperating agencies, with extensive stakeholder engagement, public hearings, scoping meetings, and consultations. 

Following legal challenge of the 2020 final decision, BLM was ordered to conduct further environmental analysis, including potential impacts of greenhouse gas emissions and mitigation measures. The Supplemental addresses the concerns presented by the court and the analysis clearly supports permitting this project.

BLM proposes a new action alternative – Alternative E. RDC also supports Alternative E, which reduces the scope, the footprint and impact of the project and addresses the courts concerns. Alternative E also addresses concerns by Project opponents:  it reduces and realigns the number of drilling sites (from 5 down to 4, but only 3 would be approved as currently proposed in the DSEIS); reduces the amount of roads, both gravel and ice, which also reduces freshwater usage; reduces the amount of infield pipelines; realigns the Project to avoid yellow-billed loon buffer zones; and reduces the length of airstrips. Most of these reductions take place in or near the Teshekpuk Lake Special Area (TLSA); again, an area of most concern to opponents. 

Further, the supplemental analysis of greenhouse gas (GHG) emissions conducted in response to the court’s order proves Alternative E has the lowest overall impacts than any other action alternative based on current U.S. standards for modeling greenhouse gas emissions. 

RDC acknowledges that there are special interests that oppose any further development of any fossil fuels in the Arctic and elsewhere. However, despite increases in alternative energy sources, the majority of these growing energy demands will be satisfied through the use of fossil fuels. RDC believes these resources should be developed and produced here in Alaska where operations and emissions are strictly regulated and best management activities are employed.  

The science-backed data supports the conclusion that the Willow Project is an environmentally and socially responsible resource development project. With its smaller footprint, this Project will play a critical role in the clean energy transition. RDC encourages BLM to adopt Alternative E and permit the Project without further delay. Thank you.