Comment Letter on the National Petroleum Reserve-Alaska Integrated Activity Plan

January 11, 2019

Mr. Ted Murphy, State Director
BLM Alaska State Office
222 W. 7thAvenue, Mailstop 13
Anchorage, AK 99513-7504

Re: Call for comments for National Petroleum Reserve-Alaska Integrated Activity Plan

Dear Mr. Murphy:

Thank you for the opportunity to submit comments on the planning efforts underway to develop a new management strategy for the National Petroleum Reserve-Alaska (NPR-A) consistent with Secretarial Order 3352. 

Given the outstanding track record of the oil and gas industry in the Alaska Arctic, as well as the technological advances of the past 40 years, the Resource Development Council for Alaska, Inc. (RDC) supports the development of a new Integrated Activity Plan (IAP) for NPR-A that strikes a more appropriate balance between energy development and protection of surface resources. The IAP should reopen all of NPR-A’s subsurface historically available to oil and gas leasing. In addition, the Bureau of Land Management (BLM) should update provisions for transportation corridors inside NPR-A to facilitate future resource development.

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.

Expanded oil and gas development and production in Alaska will help strengthen American energy independence, advance domestic energy production, and support local job growth. However, the 2013 Integrated Activity Plan for NPR-A unnecessarily prohibits leasing and development of potentially oil-rich lands in much of Northeast NPR-A south of Teshekpuk Lake that had been opened to development. The 3.1 million acres in Northeast NPR-A closed to leasing under the 2013 IAP was an overreach. Oil and gas leasing and exploration has occurred on these lands in the past and should be allowed going forward. 

In 1923, Congress designated NPR-A, an area larger than the state of Maine, for energy production. In planning for future development, BLM can deploy reasonable mitigation measures to protect surface resources important to local residents for subsistence needs and the environment. 

Decades of oil and gas activity on the North Slope clearly demonstrate industry has the ability to operate throughout the Arctic while maintaining the highest standards of safety and environmental sensitivity. New

advances in technology have greatly reduced the footprint of development, allowing for greater consolidation of facilities and the preservation of more acreage within development zones for wildlife habitat. For example, as much as 60-plus square miles can now be developed from a single 12 to 14 acre gravel drill site. New drilling capabilities are being developed that may increase the subsurface development possible from the same size drill site to as much as 150-plus square miles. The net effect is an ever-decreasing impact on surface resources. 

The discovery and development of new oil and gas deposits will benefit Alaska and local communities. State and local revenues derived from production will help sustain important state services. New industry activity will also provide thousands of job opportunities, boost the local, state, and national economy, and refill the Trans-Alaska Pipeline System (TAPS), which is currently running at three-quarters empty. Development of new energy deposits will also reduce reliance on imported oil and help establish American energy dominance. 

Given NPR-A was specifically designated by Congress for the production of energy resources, it is important BLM provide access to prospects with the highest potential. North Slope oil and gas deposits have occurred almost exclusively within a 25-mile strip of the Beaufort Sea coastline – a geologic structure known as the Barrow Arch. Several large discoveries have been announced in recent years within the arch in two little-explored reservoirs that extend into the energy reserve – the Nanushuk and Torok formations. Exploration efforts targeting the Nanushuk formation in 2015 resulted in a major discovery in the Pikka Unit, an area comprised of State of Alaska leases north of the village of Nuiqsuit. Two wells drilled in 2017 at a prospect known as Horseshoe showed new evidence of a large find that extended the already huge Nanushuk play by an additional 20 miles.  The Horseshoe wells confirmed the Nanushuk reservoir as a significant emerging opportunity on the North Slope and a potential game changer with billions of barrels of conventional oil. Geologists believe the discoveries in the relatively shallow reservoir increase the likelihood of large oil discoveries in NPR-A. 

In addition, a major discovery of at least 300 million barrels of oil has occurred at the Willow prospect in Northeastern NPR-A and early exploration hints at a potential multi-billion barrel field at Smith Bay, located in state waters off the northern coast of the energy reserve. More than 500,000 barrels a day in new production could come from these and other projects on state and federal lands in the area.

The highly-promising Nanushuk reservoir indicates NPR-A’s energy reserves may be much higher than estimated under the previous administration. Federal geologists estimated the energy reserve contained approximately 10 billion barrels of recoverable oil, but those projections were sharply reduced to less than 850 million barrels in 2010. Following that dramatic revision, nearly half of the reserve was put off-limits to development, including large swaths of highly-prospective lands within the Barrow Arch. However, in light of the recent finds, the U.S. Geological Survey has since revised its mean estimate of oil reserves in NPR-A to approximately 8.7 billion barrels.

RDC is concerned with the alarming trend over the past two decades of “locking up” oil-rich lands in NPR-A and the Alaska Arctic Outer Continental Shelf. We are very much concerned that the trend clearly has been toward less leasing and less access. Much of the most prospective acreage within the Barrow Arch has now been removed from leasing, including those closest to potential future production. It is important to remember this is a petroleum reserve.

RDC strongly supports the BLM writing a new Integrated Activity Plan for NPR-A to incorporate the most current information and develop new management goals, objectives, and actions that would be consistent across the entire energy reserve. It is our hope that such efforts will re-open oil-rich areas in the northeastern areas of the reserve. 

RDC recognizes coastal areas of the petroleum reserve contain large populations of waterfowl and caribou and are valued by local residents for subsistence hunting. However, a variety of protective measures, operating procedures, standards, and stipulations are employed to mitigate impacts of energy development on other land uses and resources in areas where development currently occurs on the North Slope. We urge BLM to provide access to NPR-A’s prospective acreage while providing reasonable measures to mitigate impacts. These measures should be both technically and economically feasible. 

RDC believes it is unnecessary for BLM to keep closed highly-prospective acreage in NPR-A to future lease sales. If BLM removes the best prospects from future leasing, there is unlikely to be significant industry interest going forward in the energy reserve. If these areas remain closed to leasing and exploration, then a significant portion of the energy reserve’s potential will be unrealized and industry’s interest and investment will move elsewhere beyond Alaska, weakening the local and statewide economy.

Ironically, had sensitive wildlife and wetland areas along the central coastal plain been withdrawn from exploration in the 1960s, there would have been no discovery of oil at Prudhoe Bay, Kuparuk, and other North Slope oil fields. Alaska would not have the economy and public infrastructure it has in place today, and the nation would have been forced to import at least an additional 17 billion barrels of oil over the past 40 years at a staggering cost. Instead, North Slope oil fields have elevated Alaska’s economy over the past four decades. In addition, the Central Arctic caribou herd population has grown from 5,000 animals in 1970 to over 60,000 in recent years, demonstrating oil and gas development can coexist with wildlife and the environment. 

In addition to reopening areas historically available for leasing, RDC encourages the BLM to give serious consideration to a year-round road system within NPR-A to connect local communities. An overland transportation system would provide local residents direct access to their communities and facilitate response to emergencies within the reserve. 


As the BLM begins the process of revising the management plan for NPR-A, we encourage the agency to ultimately produce a plan that demonstrates federal lands in Alaska are open for business. 

The development of new energy deposits in NPR-A will benefit Alaska, local communities, and the nation. Revenues derived from new production will help sustain important state services. Industry activity will also provide new job opportunities for local residents and others while boosting the economy. Increased access to NPR-A should be accommodated with provisions to protect the traditional ways of life, especially the subsistence needs of Northwest Alaska residents. Re-opening highly-prospective areas of NPR-A to future lease sales would advance the President’s goal of American energy dominance.

Thank you for the opportunity to provide comments on the development of a new Integrated Activity Plan and associated Environmental Impact Statement for NPR-A.

Resource Development Council