Anchorage, AK 99513-7504

Re:       Comments on the Willow Master Development Plan (MDP) Draft Supplemental Environmental Impact Statement (DSEIS); NEPA # DOI-BLM-AK-0000-2018-0004-EIS

Dear State Director Cohn:

The Resource Development Council for Alaska, Inc. (RDC) submits the following comments to the Bureau of Land Management’s (BLM) above-referenced document. RDC is a statewide trade association comprised of individuals and companies from Alaska’s fishing, tourism forestry, mining, and oil and gas industries. RDC’s membership includes Alaska Native corporations, private companies, nonprofit entities, local communities, organized labor, and industry support firms. For 47 years, RDC has advocated for a strong, diversified private sector in Alaska and to expand the state’s economic base through the responsible development of our natural resources. The Willow Project is such an example.

RDC encourages the BLM to move forward in finalizing the DSEIS without any further delay or extensions. After many years of rigorous environmental review and analysis, including complying with additional court-ordered review, the DSEIS presents a reasonable alternative that responds to the court’s concerns and was developed in coordination with cooperating agencies and stakeholders. The current comment period is adequate time to review limited, new information. 

• Extensive Analysis and Public Input; Court Concerns are Addressed

Since 2017, RDC has submitted several comments letters and testified in support of the Willow Project. RDC continues to support the project in this current phase of review. The extensive effort and scientific analysis BLM and other cooperating agencies provided culminated in a FEIS and ROD in 2020 approving the Project. BLM’s extensive analysis was in cooperation with multiple state, federal, and local cooperating agencies, with extensive stakeholder engagement public hearings, scoping meetings, and consultations. This includes now approximately 215 days of days of public comment (including this current comment period), two public scoping periods, and thirteen in person public meetings held in Anchorage, Fairbanks, Nuiqsut, Utqiagvik, Atqasuk, and Anaktuvuk Pass. (It is important to emphasize this does not count the extensive and numerous efforts the BLM staff engaged in to find new ways to continue to engage the public and progress permitting when the pandemic hit in 2020, including holding virtual meetings to allow public engagement virtually by phone, virtual conferencing, and local radio broadcasts. By some counts, these additional meetings bring the number of public meetings closer to 25.)  RDC applauds the extensive efforts of BLM to engage in a thorough, multi-year analysis of the project based in science and supported by the research; however, it is time to bring that process to a close and let the project proceed to development. 

This current phase of review, the DSEIS, is the result of a remand decision in August 2021, by the U.S. District Court for Alaska. That remand order, which was not contested by the Project Proponent, identified specific categories of deficiencies that required additional analysis. In response, this past spring, BLM opened a public scoping period to assess the scope of the additional court-ordered review. RDC submitted comments encouraging BLM to focus solely on the narrow issues identified by the court remand decision. Importantly, multiple other aspects of the 2020 Willow MDP FEIS were unaffected by the court’s remand decision. The unaffected parts of the previous environmental review for the Willow Project do not need to be revisited. 

Upon initial review of the DSEIS, RDC applauds BLM for maintaining a narrow focus to the court issues and commonsense approach to this years-long, extensive environmental review of the Willow MDP. The DSEIS makes it easy to identify the new analysis and the new “Alternative E: Three-Pad Alternative (Fourth Pad Deferred)” (“Alternative E”) developed in direct response to the court order. The current comment period is more than adequate to review the limited new information and comment. Further delay will only add to additional, unnecessary costs and cause potential loss of another valuable construction season. 

Alternative E reduces the scope, and consequently, the footprint and impact of the project. In several ways, this addresses many concerns most often expressed by Project opponents. First, it reduces and realigns the number of drilling sites (from 5 down to 4, but only 3 would be approved as currently proposed in the DSEIS). Alternative E further reduces the amount of roads, both gravel and ice, needed for the Project, which also reduces freshwater usage; reduces the amount of infield pipelines; realigns the Project to avoid yellow-billed loon buffer zones; and reduces the length of airstrips needed. Most of these reductions take place in or near the Teshekpuk Lake Special Area (TLSA); again, an area of most concern to opponents. Additionally, in its updated analysis of greenhouse gas (GHG) emissions as part of the Climate and Climate Change analysis and in response to the court’s remand order, the DSEIS concludes Alternative E has the lowest overall GHG impacts than any other previously considered action alternative based on current U.S. standards for modeling GHG impacts. The DSEIS adequately addresses both the direct and indirect as well as cumulative GHG impacts of the Project. Further review concludes cumulative impacts on coastal subsistence communities is expected to be low. Overall, proposed Alternative E reduces the footprint and surface infrastructure of the project within TLSA presenting a reasonable path forward supported by BLM’s environmental analysis. The DSEIS directly addresses the court’s concerns. 

• The Willow Project Brings Economic and Energy Independence for All

RDC understands that Alternative E was developed by BLM together with cooperating agencies and stakeholders as a compromise to address the court’s concerns. Key stakeholders for this project include Alaska Native individuals, communities, and entities of Alaska’s North Slope region. The project falls within the North Slope Borough (NSB), whose territory includes the NPR-A. Key villages within the NSB include Nuiqsut, Utqiagvik, Point Lay and Wainwright. Other key Alaska Native entities include the Inupiat Community of the Arctic Slope (ICAS), the Arctic Slope Regional Corporation (ASRC), the Alaska Native regional corporation for the North Slope established pursuant to the Alaska Native Claims Settlement Act of 1971 (ANCSA). Representing more than 10,000 Alaskans and Alaska Native individuals, these stakeholders overwhelmingly support the Willow Project. RDC encourages BLM to give all due respect to the cultural and economic arguments, including subsistence concerns, set forth in a joint letter by ICAS, ASRC, and the NSB dated July 21, 2022, and that was recently submitted to the public record for this Project.

The Willow Project is in the National Petroleum Reserve-A (NPR-A), a 23-million acre reserve specifically set aside by Congress in 1923 for its petroleum value to ensure American energy independence. The NPR-A is larger than the state of Maine and the Willow Project represents just a small fraction of that area. With Alternative E, that fraction becomes even smaller. The Willow Project will provide key economic investment at all levels of government, as well as the private sector. The Willow Project is estimated to contain as much as 600 million barrels of oil and peak daily production could exceed 180,000 barrels per day over a thirty-year period. This production would substantially boost throughput in the Trans-Alaska Pipeline System (TAPS), running at times one-fourth of its capacity, and will extend the life of TAPS for decades to come. It is estimated the Project will provide nearly $9 billion in economic benefits through federal, state, and local government royalties and revenues from production, as well as property and income taxes. More than 2,000 construction jobs will be created, including 300 long-term jobs in Alaska. Clearly, Willow production will help fulfill the primary purpose of the NPR-A, which is to develop American energy resources. It is paramount that BLM provide access to prospects in this region with the highest potential as Congress intended.

In closing, after several years of rigorous environmental review, extensive regulatory assessment, court review, and supplemental analysis, it is time to permit this project. The science-backed data supports the conclusion that the Willow Project is an environmentally and socially responsible resource development project. With its smaller footprint, this Project will also play a critical role in the clean energy transition. RDC encourages BLM adopt Alternative E and permit the Project without further delay. 

Thank you for allowing RDC to comment on this important project.