Comment letter on Willow Supplemental Draft EIS

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May 4, 2020

Mr. Chad Padgett, State Director
Bureau of Land Management
222 W. 7th Avenue, Stop #13
Anchorage, AK 99513-7504

Re: Willow SDEIS comments

Dear Mr. Padgett:

The Resource Development Council for Alaska, Inc. (RDC) is writing to express strong support for Alternative B and module transfer Option 3 in the Supplemental Draft Environmental Impact Statement (SDEIS) for the Willow project within the National Petroleum Reserve-Alaska (NPR-A).

RDC is statewide trade association comprised of individuals and companies from Alaska’s fishing, forestry, mining, oil and gas, and tourism industries. RDC’s membership includes all 12 land-owning Alaska Native corporations, local communities, organized labor, industry support firms, and thousands of Alaskans supporting responsible development of Alaska’s natural resources. 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.

The SDEIS includes a wide range of alternatives which contain measures to avoid or mitigate surface impacts and minimize ecological disturbance throughout the program area. Alternative B reflects feedback from North Slope stakeholders that would further minimizes the impact of the project. Option 3 also addresses concerns from North Slope communities about a gravel island’s potential impacts on marine mammal subsistence activities and decreases the amount of gravel needed for the project. The revisions to the project studied in the SDEIS clearly demonstrate the applicant’s willingness to work with communities to minimize impacts of the project.

In addition to minimizing impacts, Alternative B maintains high standards for safety and emergency response and leverages contemporary North Slope best management practices to avoid and minimize impacts. It would reduce environmental impacts compared to other alternatives by using less gravel fill, fresh water, and aircraft flights, while improving year-round access for local residents.

Industry and the State have made great strides in designing responsible development plans in the Arctic with minimal impact on the environment, wildlife, subsistence harvest activities, and cultural traditions. Extensive mitigation and engineering design features are incorporated into the Willow project. The industry has learned a lot since Prudhoe Bay was first developed and minimizing environmental impact is a core driver in the Willow oilfield design.

Energy from Willow is an important resource for meeting our nation’s energy demands and achieving energy dominance, even during these temporary low consumption times due to the COVID-19 pandemic. Production from Willow could serve to help maintain the integrity of the Trans-Alaska Pipeline System, a critical link to America’s energy distribution. Given the vast resources believed to be available in NPR-A, future production from Willow and other fields would reverse the decline in TAPS, allowing it to remain viable for decades.

Development of the proposed $4-$6 billion project could provide benefits to the local and state economies through local hire for jobs created during construction and operations, tax revenues, federal revenue sharing from royalties and lease rentals and new resources to help meet domestic energy demand. The project could create more than 2,000 construction jobs and 300 permanent jobs at a time when Alaskans need jobs. Moreover, the BLM estimates that Willow could generate more than $10 billion dollars in federal, state, and North Slope Borough revenue.

Production from Willow is compatible with the purpose of NPR-A which is to develop America’s energy resources. The 23-million acre reserve was set aside nearly a century ago for its petroleum value. In an updated report, the U.S. Geological Survey estimates the reserve could hold nearly 9 billion barrels of oil.

Despite the many benefits Willow would bring to Alaska and the nation, there are special interests that are opposed to further development of Arctic energy resources. They advocate leaving oil in the ground, but even in an era of climate change, reality requires continued development of America’s oil and gas resources, especially in the vast NPR-A.

We don’t deny renewable energy is a growing part of America’s energy portfolio, but it is still only projected to account for a minority of American energy production in 2040. New oil and gas production will be required to power America’s economy and can serve as a bridge until renewable energy becomes a dominant energy source decades into the future. Every barrel of oil not developed in Alaska will simply be imported from overseas where environmental regulations are often weaker and the carbon footprint is larger. To further reduce our reliance on foreign sources of oil, America must continue to pursue responsible oil and gas development in NPR-A.

RDC applauds the Bureau of Land Management (BLM) for finding new ways to continue to engage the public and progress permitting of the Willow project during the pandemic. BLM has made a genuine and extensive effort to provide opportunities for meaningful comment. It has held eight virtual meetings with Zoom and has employed call-in options using telephones, live streaming on Facebook, and hard copies of the SDEIS mailed to North Slope communities. In addition, BLM has coordinated with the North Slope radio station KBRW to air its presentations in Inupiat. Your agency has continued to accept comments through traditional means such as letters and email. Yet despite these efforts, opponents of the project are demanding a halt to the process until the pandemic passes. We believe their demands are unreasonable and are nothing more than a delay tactic to derail the project.

RDC agrees with the State of Alaska in a letter it sent to the Bureau of Land Management on April 3rd, 2020 which states: “This project will bring critical revenue and jobs to the State and the nation during an essential time where both will need to recover from the economic impacts resulting from COVID – 19. If the Willow project stays on its current timeline it will significantly help the State recover from the current fiscal situation and COVID-19 impacts. If BLM’s EIS process experiences future and further delays the State will certainly, and unnecessarily, experience prolonged economic impacts.”

Significant public engagement has occurred to date through public scoping and public comments on the SDEIS. BLM’s current SDEIS comment period should not be paused – there has been ample opportunity for comment.

In concluding, RDC urges BLM to move forward in a timely manner with the Final EIS and Record of Decision. Not only does Alaska need oil from the Willow project, but America will benefit from it too. Thank you for the opportunity to submit comments on the Willow SDEIS.