Scoping Comments on the Willow Master Development Plan Supplemental Environmental Impact Statement

RDC Action Alert 

March 9, 2022

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

Re: Scoping Comments on the Willow Master Development Plan (MDP) Supplemental Environmental Impact Statement (SEIS)

Dear Acting State Director Heinlein:

The Resource Development Council for Alaska, Inc. (RDC) submits the following comments to the BLM’s current scoping and public comment period referenced above. RDC understands this scoping period was opened as a result of a decision in August 2021, by the U.S. District Court for Alaska that vacated the Record of Decision (ROD) and Final Environmental Impact Statement (FEIS) of the Willow Master Development Plan (Willow MDP or Willow Project). By doing so, the order requires the Bureau of Land Management (BLM) to prepare a Supplemental Environmental Impact Statement (SEIS) to address deficiencies identified therein. Importantly, the court upheld multiple other aspects of the Willow MDP FEIS. RDC encourages BLM to focus solely on the narrow issues identified by the court decision as it proceeds with this phase of supplemental analysis.

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, 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.

The Willow Project is in the National Petroleum Reserve-A (NPR-A), on Alaska’s North Slope. In 1923, Congress specifically set aside and designated the NPR-A, an area larger than the state of Maine, to ensure American energy independence. The 23 million acre reserve was specifically set aside nearly a century ago for its petroleum value. The U.S. Geological Survey estimates the reserve could hold as much as 9 billion barrels of oil. Given the vast resources estimated to be in the NPR-A, future production from Willow and other fields in the NPR-A and Alaska’s North Slope could also reverse recent declines in throughput in the Trans-Alaska Pipeline System (TAPS), maintaining its viability for decades to come. It is paramount that BLM provide access to prospects in this region with the highest potential as Congress intended. The Willow Project is estimated to contain as much as 750 million barrels of oil and daily production could exceed 100,000 barrels per day through TAPS. This production would substantially boost throughput in the TAPS, running at times one-fourth of its capacity. This would also extend the life of TAPS for decades to come. Clearly, Willow production will help fulfill the primary purpose of the NPR-A, which is to develop American energy resources.

Since 2017, RDC has submitted several comments letters and testified in support of the Willow Project development over the past several years. RDC believes and 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.

The extensive effort and scientific analysis BLM and other agencies provided culminated in the ROD and FEIS. BLM’s extensive analysis was in cooperation with multiple state, federal, and local cooperating agencies, with extensive public hearings, scoping meetings, and consultations. This included more than 140 days of public comment, public scoping period, and thirteen in person public meetings held in Anchorage, Fairbanks, Nuiqsut, Utqiagvik, Atqasuk, and Anaktuvuk Pass. This does not count the extensive efforts the BLM 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, videoconference and internet conferencing, such as Zoom, and local radio broadcasts.

With respect to this current phase to supplement that analysis with a SEIS, though RDC disagrees with the final outcome of the court decision, RDC recognizes and wants to point out that a majority of BLM’s extensive and existing National Environmental Policy Act (NEPA) analysis was upheld by the court. Therefore, the supplemental analysis beyond the specific issues identified in the court order is not required nor should it be reopened as a matter of law. Specifically, the court’s order focuses on just three primary issues: climate change analysis as it relates to downstream foreign emissions; range of alternatives analysis as it relates to the extent of what is producible; and aspects of the U.S. Fish & Wildlife Service (USFW) biological opinion to specify mitigation measures related to polar bears. The proper scope of BLM’s analysis should be as limited. After more than three years of extensive scientific study, there is ample data to support the Willow MDP EIS supplemented with only the narrow information at issue in the August 2021 court order.

RDC supports the Willow Project and believes expanded oil and gas development and production in Alaska will help strengthen the American economy, our energy independence, advance domestic energy production, and support local job growth. Development of the Willow Project is an important resource for meeting out nation’s energy demands and achieving energy dominance, especially during times when a global pandemic has resulted in supply issues, rising energy costs as a result of unprecedented inflation, and especially now as the United States just announced a ban on all foreign imports of Russian energy, including oil and gas, due to the escalating actions of Russian President Vladimir Putin waging a senseless war against the people of Ukraine. Now more than ever, the Willow Project serves as a critical link to America’s energy independence.

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