September 6, 2018

Mr. Ted Murphy, Alaska State Director
Willow MDP/EIS Scoping Comments
Bureau of Land Management
222 West 7th Avenue, Stop #13
Anchorage, AK 99513 

Dear Director Murphy: 

I am writing on behalf of the Resource Development Council for Alaska, Inc. (RDC) to express support for the development of the Willow prospect within the National Petroleum Reserve-Alaska (NPR-A). RDC also supports the preparation of the Master Development Plan Environmental Impact Statement (MDP/EIS) in accordance with the recently issued Executive Order and Secretarial Guidance on streamlining and improving the National Environmental Policy Act and other regulatory processes. 

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. 

In the EIS, BLM should clearly outline the substantial social and economic benefits of the Willow prospect to the North Slope Borough, the State of Alaska, and the nation, including the billions of dollars generated for the NPR-A Impact Mitigation Grant Program, which will focus on local communities and impacted areas. 

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 help meet domestic energy demand. Clearly, Willow production would help fulfill the primary purpose of NPR-A, which is to harvest American energy resources. 

Production from the $5 billion Willow project would generate billion 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 for local residents and other Alaskans. These would be high-paying, year-round jobs that would sustain Alaskan families and benefit local communities in many ways. Overall, the activity and revenues generated by this major project would substantially boost Alaska’s economy, which is has been stuck in a recession for approximately three years. 

Moreover, the project would also deliver the positive benefits of new roads on subsistence hunting. Roads built for other nearby projects have benefited subsistence hunters by providing timely, safe, and affordable access to the resource. Roads also insure that the operator can respond to any medical, environmental and safety issues in a harsh Arctic environment in an adequate and timely manner. These positive aspects should be acknowledged in the MDP/EIS. 

When it comes to the environment, industry has a solid track record of conducting its operations in a responsible manner, which respects and protects the subsistence way of life. 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 on the environment, wildlife, and subsistence activities. With regard to Willow, the project will utilize existing road and pipeline infrastructure in the Colville River and Kuparuk River Units to minimize impacts. 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 indispensible 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, and as along as there is a market for oil and gas, the resources should be developed and produced here where operations and emissions are strictly regulated and best management activities are employed to avoid and minimize impacts. 

In conclusion, RDC is fully confident the Willow project will be developed in a responsible manner with minimal impacts to the environment and subsistence resources. The BLM should prepare the MDP/EIS in accordance with the recently issued Executive Orders on streamlining and improving the NEPA process. The agency should also clearly state and the many positive socio-economic benefits of the project to the region, state, and nation. 

Thank you for the opportunity to comment on this important project.