August 12, 2022

Submitted electronically via: https://www.regulations.gov/commenton/DOE-HQ-2022-0019-0001

Re:       Comments on the Alaska LNG Draft Supplemental Environmental Impact Statement Docket Number: DOE-HQ-2022-0019-0001

Dear Mr. Lusk:

The Resource Development Council for Alaska, Inc. (RDC) is writing to encourage the U.S. Department of Energy (DOE) to move expeditiously to a Final Supplemental Environmental Impact Statement (FSEIS) and a positive Record of Decision (ROD) on the Alaska Liquified Natural Gas Project (Alaska LNG Project or Project) following its release of the Draft Supplement Environmental Impact Statement (DSEIS) dated June 24, 2022. The DSEIS further substantiates the Alaska LNG project is an environmentally, economically, and socially responsible development project that should move forward. It would be one of the most important projects to Alaska’s economy and the estimated $38.7 billion project would be the largest integrated natural gas/LNG project of its kind. 

RDC is a statewide, non-profit, trade association comprised of individuals and companies from Alaska’s fishing, tourism, forestry, mining, and oil and gas industries. RDC’s membership includes Alaska Native corporations, private companies, nonprofit entities, local communities, organized labor, and industry support firms. For 47 years, RDC has advocated for a strong, diversified private sector in Alaska and to expand the state’s economic base through the responsible development of our natural resources. The Alaska LNG Project is such an example.

• Extensive environmental analysis that previously supported permitting the Alaska LNG Project has not changed.

This Project has been extensively studied by DOE, FERC, and many cooperating agencies between 2014 and 2020. In 2020, FERC issued, and DOE ultimately adopted, FERC’s Final Environmental Impact Statement published March 16, 2020 (2020 EIS). Subsequently, FERC issued an order on May 21, 2020, authorizing the project proponent, the Alaska Gasline Development Corporation (AGDC), to site, construct, and operate the proposed Alaska LNG project. Following that, DOE issued a Record of Decision on August 20, 2020, and an order authorizing Alaska LNG to export to non-free trade agreement countries. In September 2020, the Sierra Club filed a legal challenge and, following rehearing by DOE, DOE prepared the current Draft SEIS for review of the authorization for export of Alaska LNG to non-Free Trade Agreement countries, and to assess the Project relative to two Executive Orders: E.O. 13990, Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis, and E.O. 14008, Tackling the Climate Crisis at Home and Abroad.

The 2020 EIS found that most project impacts would not be significant and would be reduced to minor impacts with the implementation of proposed avoidance, minimization, and mitigation measures. Moreover, a 40-plus year track record in Alaska has demonstrated that oil and gas development can coexist with traditional subsistence activities, cultural resources, wildlife, and the environment. The Draft SEIS does not alter these findings but supplements analysis on potential upstream and downstream impacts, including global greenhouse gas (GHG) emissions.

• New Analysis Finds Minimal Upstream Impacts and Lower GHG Emissions will be achieved by development of the Alaska LNG Project. 

The Draft SEIS further supplements FERC’s comprehensive 2020 EIS, which includes more than 5,000 pages of analysis, 12 scoping meetings, extensive public comment periods, contact with 78 Alaska Native Tribes involved in the 2020 EIS, and input and coordination with no less than 9 federal cooperating agencies. The Draft SEIS provides an additional 1,000 pages of comprehensive analysis of potential upstream impacts of the Project together with a full lifecycle assessment of GHG emissions. 

Notably, the Draft SEIS finds that no potential upstream resource impacts were ranked “significant” or “adverse” but may have impacts that are “negligible” or “less than significant” across a range of 19 resource categories. The cumulative impact assessment concludes any identified upstream impacts can be mitigated. DOE further concludes there is sufficient gas to supply the entire 30-year term of the export license for the Project without needing additional exploration. 

Further, the Draft SEIS concludes what RDC previously commented on with respect to GHG emissions: that the Project will not increase or will have lower GHG emissions than LNG from other sources. In 2019, RDC previously commented that the project would reduce GHG emissions in Alaska through the use of natural gas. Through potential sales, it would also help reduce GHG emissions and provide clean energy to a significant portion of the world population. The Draft SEIS validates that previous assessment. The Draft SEIS assessment conclusively finds that building the Project will result in lower GHG emissions than if the Project is not built. Most of the LNG from Alaska will be exported to Asian markets currently served by LNG from the Gulf Coast.  This will reduce emissions because ocean shipping routes from Alaska to Asia are much shorter than routes originating from the Gulf Coast. Importantly, the Draft SEIS specifically recognizes the important role of natural gas in meeting long term global emissions reductions as a continued source of energy for electricity generation around the world as other countries, particularly Asian countries move away from coal as their largest source of energy.

• The Alaska LNG Project will provide significant economic, social, and environmental benefits to Alaskans.

The Alaska LNG Project will provide significant economic benefits to Alaskans from the Arctic coast to the southern reaches of the state through the creation of thousands of jobs and billions of dollars in new revenues to the State of Alaska and the federal government. Other benefits include access to a generation of domestically produced clean natural gas for homes and businesses. The project is expected to generate 12,000 direct jobs during peak construction and approximately 1,000 long-term jobs during operation.

Connection to the Interior Gas Utility in Alaska will provide a long-term, economic energy supply for Fairbanks and interior communities who suffer from high energy prices and air quality issues due to the need to warm homes using wood-burning stoves. Interconnection of the main gas pipeline to the existing Southcentral pipeline network would provide long-term energy supplies for residential, commercial, and industrial users. The additional in-state natural gas could also support new resource development projects in need of affordable energy. 

In closing, 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 Alaska could ultimately prove indispensable as forecasts indicate our nation’s energy demands will only continue to increase. Despite sharp increases in alternative energy sources, most of the growing energy demand will continue to be satisfied using fossil fuels as part of a clean energy transition. As long as there is a market for oil and gas, Alaska’s significant 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.  

After nearly eight years of rigorous environmental review, extensive regulatory assessment, court review, and supplemental analysis, it is time to permit this project. The science-backed data supports the conclusion that the Alaska LNG Project is an environmentally and socially responsible resource development project. RDC encourages DOE to move forward to the FEIS and a positive Record of Decision. Thank you for the opportunity to comment.