ACTION ALERT: OPPORTUNITY TO COMMENT
SUPPORT RESCINDING OF THE DOI 2024 NPR-A RULE
COMMENT DEADLINE: AUGUST 4, 2025
                                                                                                                                        RDC Comment Letter
 

Dear RDC Members and Supporters,

On May 7, 2024, the Department of the Interior (DOI) published new regulations regarding the 2024 National Petroleum Reserve-Alaska Rule (2024 NPR-A Rule) that severely restricted future energy development in the NPR-A. On June 6, 2025, the DOI published a proposal to rescind this 2024 NPR-A Rule, which was fast-tracked without adequate time to properly review and assess the real impacts. The DOI also neglected to properly consult with the indigenous communities as required by law, among other legal deficiencies, and were in contravention of department policies respecting consultation during subsistence periods during the 2024 rulemaking process. Rescission of the 2024 NPR-A Rule is open for public comment through August 4, 2025. This recission was also ordered by Executive Order 14153, Unleashing Alaska’s Extraordinary Resource Potential.

Background: The 23 million acres contained in the NPR-A were set aside by the federal government in 1923, and directed by Congress in the Naval Petroleum Reserves Act of 1976, specifically for natural resource development, balanced with conservation, to promote America’s national security through energy resources, and it is an asset to the State of Alaska.  Responsible development in the NPR-A supports our nation’s energy security, well-paying jobs and economic benefits for local Alaska Native communities and the state as a whole. The 2024 NPR-A Rule effectively makes it impossible for future oil and gas lease sales and development to occur by creating a presumption against future permitting.  This is a bad policy that does not support Alaska Native communities, organized labor, or our energy independence.

LINKS:

TALKING POINTS TO CONSIDER IN YOUR LETTER:

  • Comment letters can be brief, expressing support for the June 6 proposal to rescind the 2024 NPR-A rule that was adopted under the Biden administration.
  • The 2024 NPR-A rule includes a presumption against approving oil and gas activities in the NPR-A, driving investment away from Alaska.
  • The 2024 rule effectively shuts down the NPR-A to future leasing and future investment in new developments.
  • Rescission of the 2024 rule is part of the Executive Order that aims to unleash Alaska’s energy potential.
  • Stakeholders throughout Alaska strongly opposed the 2024 NPR-A rule when it was proposed.
  • Multiple Alaska entities challenged the validity of the 2024 rule in federal court, including the North Slope Borough, the Alaska Oil and Gas Association, and The VOICE of the Arctic Inupiat. Those lawsuits are now stayed pending completion of the administrative rescission process.
  • Alaska and the nation would benefit from going back to a balanced approach to NPR-A management that follows the IAP process (Integrated Activity Plan) and provides a reasonable permitting program for responsible development of NPR-A leases.
  • BLM should complete the rescission process with final action as quickly as possible, while taking the time needed to build a strong administrative record and respond carefully to public comments in anticipation of the litigation we expect will follow.

HOW TO SUBMIT COMMENTS: Please submit a written comment SUPPORTING RESCISSION of the rule by August 4, 2025. 

Public comments can be submitted using the following methods:

The Honorable Douglas Burgum
U.S. Department of Interior
11849 C Street, N.W.
Washington, D.C., 20240

MORE POINTS TO CONSIDER:

The 2024 NPR-A Rule is a Threat to America’s Energy Security:
-    Analysis from the U.S. Geological Survey estimates there are 8.7 billion barrels of undiscovered oil in the NPR-A, an area set aside by the Federal government specifically for petroleum development.
-    By denying or dramatically restricting development in the region, the 2024 NPR-A Rule is denying Alaskans—and all Americans—reliable, affordable energy, as well as billions of dollars in revenues.
-    We cannot afford to further limit U.S. production, which will only increase our reliance on foreign nations, including adversarial nations, amid rising geopolitical threats.    
-    Oil production on the North Slope and in the NPR-A contributes to the Trans-Alaska Pipeline System (TAPS), a vital piece of U.S. infrastructure. 
-    Oil produced in the NPR-A will keep TAPS economically viable and capable of providing oil to the rest of the United States and beyond. 

The 2024 NPR-A Rule Discourages Future Investment in the Region:
-    The “bait-and-switch” nature of the 2024 rule stifles any future development in currently approved areas of the NPR-A as companies will be wary to invest into developments in areas where the government can seemingly outlaw further development without cause.