October 29, 2019                                                                                                                
                                                                                                                                             

Mr. Chad Padgett, State Director
Bureau of Land Management
222 W. 7thAvenue, Stop #13
Anchorage, AK 99513-7504

Re: Willow MDP DEIS Comments

Dear Mr. Padgett:

The Resource Development Council for Alaska, Inc. (RDC) is writing to provide comments on the Master Development Plan Draft Environmental Impact Statement (MDP/DEIS) for the Willow prospect within the National Petroleum Reserve-Alaska (NPR-A). RDC supports the proposed MDP, the Preferred Alternative (Alternative B), and Module Transfer Option 1.

RDC is a statewide non-profit business association comprised of individuals and companies from Alaska’s oil and gas, mining, forest products, fisheries and tourism industries. RDC’s membership also 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 supports the responsible development of the Willow prospect and the preparation of the MDP/DEIS in accordance with the Executive Order and Secretarial Guidance on streamlining and improving the National Environmental Policy Act (NEPA) and other regulatory processes.

Willow is estimated to contain as much as 750 million barrels of oil with more upside potential. Daily production could exceed 100,000 barrels per day. This production would substantially boost throughput in the Trans-Alaska Pipeline System (TAPS), currently running at approximately one-fourth capacity. It would also extend the life of TAPS, a critical component of our domestic energy complex and Alaska’s economy. Willow production would also help fulfill the primary purpose of NPR-A, which is to secure American energy for domestic use and national security.

Production from the $5-6 billion investment in the Willow project would generate billions of dollars in royalties and tax revenues to the State of Alaska, the North Slope Borough and the federal government. Willow would also generate thousands of direct and indirect jobs, sustain Alaska families and benefit local communities in many ways.

In Alaska, the benefits of oil development and the spending of state revenues generated from ongoing production are profound. Oil production has accounted for up to 90 percent of the State of Alaska’s unrestricted general fund, transforming Alaska’s economy. Community infrastructure has greatly expanded since North Slope oil production commenced in 1977 and ongoing production not only maintains such infrastructure, it allows for the continued expansion of the last frontier’s limited road system and ports. Oil revenues have been used to build new schools throughout the state, medical centers in rural areas, and facilities ranging from libraries to sports arenas. In fact, oil revenues have funded the North Slope Borough’s work to build its public water and sewer system. Without production, Alaska as a whole would have fewer public facilities. Residents would not receive Permanent Fund dividends, which are a major economic stimulus and provide essential revenue for many rural and urban households. The oil industry has a disproportionate benefit to Alaskans and the economy. 

When it comes to the environment, North Slope operators have a solid track record of conducting operations in a responsible manner, which respects and protects the environment and the subsistence way of life. The oil and gas industry also has a long history of working with all stakeholders in the Arctic and has made great strides in designing projects with minimal impact. With regard to Willow, the project will utilize existing road and pipeline infrastructure in the Colville River and Kuparuk River Units to minimize the footprint of new development. Moreover, the proposed project conforms to the BLM’s 2013 Integrated Activity Plan.

RDC acknowledges that there are special interests that oppose further development of fossil fuels in the Arctic and elsewhere. However, oil and gas development in NPR-A could ultimately prove indispensable as forecasts indicate our nation’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. 

Alternative B would reduce environmental impacts compared to other alternatives by using less gravel fill, less fresh water, and fewer aircraft flights, while improving year-round access for local residents. Road connections are required for safe and environmentally sound operations. Alternative B allows for a road connection to the Alpine field infrastructure and road connections to all drill sites.

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.

In conclusion, RDC is confident the Willow project will be developed in a responsible manner with minimal impacts to the environment and subsistence resources. The BLM should move forward expeditiously with the proposed Master Development Plan in accordance with the recently issued Executive Orders and Secretarial guidance on streamlining and improving the NEPA and other regulatory processes.

Sincerely,
RDC