November 14, 2017

Bureau of Ocean Energy Management
BLM Public Information Center
222 W. 7thAvenue, #13
Anchorage, AK 99513

Re: Liberty Draft Environmental Impact Statement comments

To Whom It May Concern:

The Resource Development Council for Alaska, Inc. (RDC) is writing to express its strong support for the Liberty project and urge the Bureau of Ocean Energy Management (BOEM) to approve the Proposed Action in the Draft Environmental Impact Statement (DEIS). 

RDC is an Alaskan business association comprised of individuals and companies from Alaska’s oil and gas, mining, forest products, tourism and fisheries industries. RDC’s membership 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.

With the Trans-Alaska Pipeline System now running at three-quarters empty, projects like Liberty need to move forward. Liberty has the potential to increase throughput in the pipeline by up to 70,000 barrels per day.  Development and production of this oil will provide economic benefits across Alaska, including tax revenue to the North Slope Borough, jobs for Alaskans, and new opportunities for Alaska businesses. 

While Alaska remains in the grip of a prolonged recession, it is still a state rich in oil with billions of barrels yet to be developed and produced. In fact, there is more conventional oil remaining in place in the Alaska Arctic than what has been produced in the 40 years since production began on the North Slope. Liberty and other potential North Slope projects combined can refill TAPS and help grow Alaska’s economy out of recession. 

RDC is confident the Liberty reservoir can be developed in an environmentally-responsible manner. Hilcorp will utilize technology that has been safely used in other Arctic offshore development over the past 30 years. The Liberty Development and Production Plan incorporates key elements of the previous EIS and uses concepts approved in the prior EIS, including the location of the proposed gravel island, island construction, on-island drilling and processing facilities, and pipeline routing to the coast. 

Artificial gravel islands are not new to Alaska’s Arctic and have a long track record of safe operations. These islands have proven to be a responsible means for oil and gas development in the Beaufort Sea. The Endicott oil field uses man-made islands for its operations, which were constructed nearly 30 years ago. Moreover, the Oooguruk, Northstar, and Nikaitchuk fields currently produce oil from artificial islands. The initial discovery of Liberty itself occurred in the 1980s from islands constructed in 1981-82. Overall, 18 gravel islands have been constructed for exploration and/or development of oil and gas off the coast of Alaska in the last 40 years.

RDC encourages BOEM to approve Alternative One, the Proposed Action in the DEIS and move forward with permitting in a timely manner. RDC appreciates the opportunity to comment on this important project.

Sincerely,

Resource Development Council for Alaska, Inc.