Letter in Opposition to BLM-2016-0001-0001

April 13, 2016

Secretary Sally Jewell
U.S. Department of the Interior
Director (630)
Bureau of Land Management
2134 LM, 1849 C St. NW
Washington, DC 20240

Attention: 1004-AE14

RE: Docket ID: BLM-2016-0001-0001

Dear Secretary Jewell:

I am writing on the behalf of the Resource Development Council for Alaska, Inc. (RDC) on the proposed Waste Prevention, Production Subject to Royalties, and Resource Conservation Rule.

RDC is an Alaskan, non-profit, business association comprised of individuals and companies from Alaska’s oil and gas, mining, timber, tourism and fisheries industries.  Our membership also includes Native regional and village corporations, local governments, organized labor and industry support firms.  RDC’s mission is to help grow Alaska’s economy through the responsible development of natural resources.

The oil and gas industry is vital part of our local, state and national economy and key to our national energy security. New burdens on this heavily regulated industry, particularly in light of low oil and natural gas prices, could have negative and significant unintended consequences on local economies, communities, small businesses, school districts, state budgets, and more. 

RDC urges you to withdraw the proposed rule. We are concerned about the impact the proposed rule could have on the ability of the oil and natural gas industry to develop resources domestically. This regulation will cost taxpayers and businesses much more in lost revenue and receipts than the expected increases in royalties.

As it is currently written, the implementation of the proposed rule will lead some operators to shut-in wells prematurely, decreasing the supply of domestic oil and natural gas, reducing royalty revenues, and driving up costs for consumers.

BLM must find a better way to address the real impediments to capturing more flared gas. Accelerating the permitting process for pipeline rights-of-way will allow energy producers to more easily capture and market gas that might otherwise be flared due to a lack of infrastructure. This in turn will provide much more value to taxpayers than the current rule would. 

Again, RDC urges the BLM to withdraw this rule and work closely with those with real-world knowledge to better understand this issue, including what solutions would be effective.


Resource Development Council for Alaska, Inc