May 2, 2018

Ms. Stephanie Rice
GMT2 Draft SEIS Comments
222 West 7^thAvenue, #13
Anchorage, AK 99513

Dear Ms. Rice:

The Resource Development Council for Alaska, Inc. (RDC) is writing in support of Alternative A, the Preferred Alternative in the Draft Supplemental Environmental Impact Statement (DSEIS) for the Alpine Satellite Development Plan (ASDP) for the Greater Mooses Tooth 2 (GMT2) project proposed by ConocoPhillips Alaska, Inc., within the National Petroleum Reserve-Alaska (NPR-A). 

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 understands this DSEIS supplements an earlier analysis of the project in the Bureau of Land Management’s 2004 ASDP. Under the Preferred Alternative identified in the DSEIS, the associated pipeline and access road would cross both Kuukpik Corporation-owned lands and federally-managed lands within the NPR-A.  The infrastructure would also connect to the Greater Mooses Tooth 1 development. 

A version of the GMT2 project was initially approved in the Record of Decision (ROD) of the ASDP in 2004 and was included as a reasonably foreseeable development in the 2012 NPR-A Integrated Activity Plan EIS and the 2014 Greater Mooses Tooth 1 (GMT1) SEIS. Under the Preferred Alternative identified in the latest DSEIS, the associated pipeline and access road would cross both Kuukpik Corporation-owned lands and federally-managed lands within the NPR-A.  The infrastructure would also connect to the GMT1 development, eight miles away.  

The project will bring meaningful benefits to local residents, the state, and the nation. Through the 7(i) provisions of the Alaska Native Claims Settlement Act, this project will provide significant revenues throughout the state through royalties and revenue sharing among Alaska Native shareholders. 

GMT2 is a $1.5 billion project, which could produce up to 30,000 barrels per day. New production would help offset declining North Slope production and help re-fill the Trans-Alaska Pipeline System, currently running at three-quarters empty. The project would create new jobs and generate revenues to the North Slope Borough, the State of Alaska, and the federal government.

The proposed project is similar to the one approved in 2004, but includes revisions to lower the overall impact of development, including a relocated drilling site outside of the Colville River Special Area, and reducing the road and pipeline length, thereby reducing the amount of fill and associated impacts to wetlands.  Relocation of the drilling pad also mitigates the potential impacts on waterfowl. As a result, Alternative A is the least environmentally-damaging alternative that meets the purpose and need for the GMT2 project. 

As proposed in Alternative A, the project would include a gravel road to existing infrastructure at GMT1. The road is necessary to insure that the operator can respond to any environmental and safety issues in an adequate and timely manner. Conversely, Alternative C, the aircraft and roadless alternative, would not allow adequate access to emergency response resources and creates increased environmental and safety risk. On bad weather days, there would be no access to GMT2. 

Of the alternatives studied, Alternative A also poses the fewest impacts to subsistence, incorporating extensive subsistence mitigation in the project design, including pipeline standards and separation from the road to ensure caribou movement, road pull-outs for safety and subsistence access, and less air traffic in the area – a direct result of year-round surface access from GMT-1. Alternative A requires less air traffic close to the community of Nuiqsut than Alternative C, and air traffic is the most frequently reported caribou hunting impact associated with development. 

With regard to lease stipulations and Best Management Practices (BMP), RDC supports the request of ConocoPhillips Alaska for a deviation from Stipulation E-2 and BMP E-7(c). Stipulation E-2 is based on the BLM 1998 Lease Stipulation 41 prohibiting oil infrastructure within 500 feet of water bodies. The original stipulation was re-designated as Lease Stipulation E-2 with the-500 foot setback restricted to fish-bearing waters. In 2004 and again in 2015, BLM approved deviations to the lease stipulations now known as E-2 because of the technical infeasibility of total compliance due to the hydrology and number of water bodies in the area, as well as implementation of other measures that would protect water bodies. 

BMP E-7(c) requires that a minimum separation distance of 500 feet between pipelines and roads be maintained to minimize disruption of caribou movement and subsistence use. However, 500-foot separation of roads and pipelines may not be feasible in narrow land corridors between lakes and where pipelines and roads converge on a drill pad. For the GMT2 project, where it is not feasible to separate pipelines and roads, BLM should approve deviation from BMP-E-7(c) and instead employ supplemental mitigation measures such as speed limits and other design and operation measures that reduce impacts to subsistence resources. 

In conclusion, RDC supports the GMT2 project as proposed in Alternative A. RDC is fully confident the project will be developed in a responsible manner with minimal impacts to the environment and subsistence resources. We urge the BLM to move forward with the timely completion of the process and a Record of Decision adopting Alternative A.