[Congressional Record Volume 171, Number 187 (Friday, November 7, 2025)]
[Senate]
[Pages S7997-S8001]
From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]
S.J. RES. 80
Mr. SULLIVAN. Madam President, I rise today to urge my colleagues to
reject the Biden administration's sweeping plan to lock down nearly
half of the National Petroleum Reserve in Alaska to responsible oil and
gas development in contradiction to congressional mandates. I urge my
colleagues to support the Alaska delegation's joint resolution of
disapproval, S.J. Res. 80, to protect Alaska's rights and future.
The implementation of the Biden administration's National Petroleum
Reserve in Alaska, NPR-A, Integrated Activity Plan, IAP, Record of
Decision, ROD, locks away more than 6 million acres previously made
available for responsible oil and gas leasing and restricts
infrastructure across 8 million acres--completely undermining the
intent of Congress and ignoring the needs and input of local residents.
Passing this joint resolution will disapprove this Record of Decision
and revert management of the NPR-A back to the previously approved
Integrated Activity Plan promulgated during the first Trump
administration.
I have long said that Alaskans are some of the foremost
conservationists in the world, with a long-standing record of balancing
conservation with responsible resource and infrastructure development.
Our oil fields on Alaska's North Slope offer a world-class example of
what it means to responsibly produce energy in a harsh and demanding
environment. The environmentally conscious way in which Alaskans have
applied cutting-edge technology is second to none, utilizing ice roads
and a winter construction season to minimize impact on Alaska's tundra.
Because of the opportunities provided by oil and gas operations, this
industry has provided thousands of good-paying jobs to Alaskans. It has
become the primary driver of my State's economy. Oil and gas revenues
fund education, essential infrastructure, and community services across
the State, making responsible resource development truly a matter of
life or death for Alaskans. In 1954, the Interior Department, with the
help of the University of Pittsburgh, conducted a study of the health
of Alaska Natives. Many of our communities in rural Alaska all had some
of the lowest levels of life expectancy in the entire world. Between
1980 and 2014, the average lifespan increased by 13 years across the
region, largely due to oil and gas revenue providing the opportunity to
install what we consider to be basic and essential community
infrastructure. To say these operations have had a positive impact on
the local communities is a gross understatement.
The North Slope of Alaska contains some of the greatest hydrocarbon
potential of any place on the planet. It is home to the Prudhoe Bay oil
field, the largest conventional oil field in North America, which has
produced over 13 billion barrels of oil since production began in 1977.
On either side of Prudhoe Bay are two Federal areas, one being the
Arctic National Wildlife Refuge and the other being the National
Petroleum Reserve in Alaska, the subject of today's legislation. The
U.S. Geological Survey this year reported that half of the estimated
undiscovered technically recoverable oil lying below Federal lands was
in Alaska, 14 billion barrels of it being on the North Slope of Alaska.
Importantly, the North Slope of Alaska is also the ancestral lands of
the Inupiat people, who have lived, subsisted, and called the Arctic
home for thousands of years. This is an area the size of Minnesota,
wholly above the Arctic Circle, with none of the communities connected
by a permanent road system, necessitating all supplies needing to be
flown or barged in. Like much of rural Alaska, it has some of the
highest costs of living anywhere in the Nation.
The discovery of Prudhoe Bay in 1968 could not have come at a more
crucial time for the United States, which was right at the height of
the Arab Oil Embargo. The barrels of crude oil from Prudhoe and
subsequent North Slope discoveries have helped ensure the American
people are not held hostage by adversarial powers seeking to use energy
as a tool of coercion. The discovery of Prudhoe Bay did not come in a
vacuum. In fact, it was long known that the North Slope of Alaska had
oil potential. In the early 1900s, as the U.S. Navy began transitioning
from coal to oil-burning engines, the Federal Government became
increasingly concerned about the supply of oil reserves in the event of
war or national emergency. In response, the Federal Government made
multiple withdrawals of public land to ensure a stockpile of fuel
supplies for the Navy remained available. The largest of these reserves
was on the Alaska North Slope and was designated by President Warren G.
Harding in 1923 as the Naval Petroleum Reserve Numbered 4, Alaska.
[[Page S7998]]
Following the discovery of oil at Prudhoe Bay and the ongoing oil
embargo, Congress passed the 1976 Naval Petroleum Reserves Production
Act, NPRPA, transferring jurisdiction of the Reserve from the Navy to
the Department of the Interior and redesignating the area as the
National Petroleum Reserve in Alaska, a 23-million-acre area roughly
the size of Indiana. A 1980 amendment to the NPRPA directed the
Secretary of the Interior to undertake ``an expeditious program of
competitive leasing of oil and gas'' in the NPR-A and also set up
revenue sharing provision between the Federal Government and the State
of Alaska that prioritized the subdivisions of the State most directly
severely impacted by oil and gas development, ensuring the people who
live in Alaska could provide for essential services.
While initial interest in the NPR-A was tepid, new oil finds closer
to the NPR-A boundaries led to a number of successful lease sales
generating millions of dollars in Federal revenues. Among the most
successful was the 2016 lease sale, which came following the discovery
of the Willow field. The Bureau of Land Management, BLM, estimates the
Willow Project will produce 576 million barrels of oil and non-gas
liquids over 30 years and generate $5.9 billion in revenue for the
Federal Government through 2053.
In 2012, the Obama administration, issued the first integrated
activity plan, IAP, addressing management for the entire NPR-A, but
only made available 11.8 million acres of the Reserve for oil and gas
leasing. Beginning in 2017, during the first Trump administration, the
Department of the Interior took steps to revise the IAP and
Environmental Impact Statement, EIS, that would strike an appropriate
balance of promoting development while protecting surface resources as
was required in the NPRPA. In December 2020, BLM released the National
Petroleum Reserve in Alaska Integrated Activity Plan Record of
Decision, the culmination of thousands of comments, over a dozen public
meetings, and the continuous involvement of the North Slope Borough,
the Inupiat Community of the Arctic Slope, the State of Alaska, and
relevant Federal Agencies. The Record of Decision selected an
alternative that made available an additional 6.8 million acres, for a
total of 18.6 million acres or 82 percent of the NPR-A's subsurface
estate, available for oil and gas leasing while ensuring lands were
made available for pipelines and other essential oil and gas
infrastructure and community infrastructure. The 2020 plan also
provided important protections for surface resources, particularly
subsistence uses by providing adequate protection for sensitive bird
populations and the Teshekpuk and Western Arctic Caribou Herds. All in
all, it was a phenomenal achievement by some very dedicated BLM
employees and an example of Federal Agencies working hand-in-hand with
Alaskans to understand our unique conditions, producing results that
protect both our environment and our way of life.
However, following the 2020 election, President Biden announced plans
to immediately review all Agency actions taken during President Trump's
term, and the Department of the Interior identified the 2020 IAP/EIS as
warranting review, one of the 70 Executive actions the Biden
administration took targeting Alaska. BLM determined that the existing
2020 IAP/EIS and associated evaluations were adequate, and no
additional analysis was necessary for the Department to select a
different alternative from the range analyzed. In April 2022, BLM
released a new record of decision that selected the No Action
Alternative identified in the 2020 IAP that effectively reverted
management of the NPR-A back to the Obama administration's 2013 IAP
ROD. The Biden IAP greatly expanded special areas within the Reserve,
prohibiting leasing on 11 million acres or 48 percent of the Reserve,
and prohibited infrastructure on approximately 8.3 million acres. The
ROD altered and expanded the Special Areas designated under the NPRPA
and established performance-based required operating procedures and
lease stipulations that applied to oil and gas leasing and development
and to some non-oil and gas activities within the Reserve. It is this
sweeping plan by the Biden administration that the passage of this
joint resolution would invalidate.
I have long said that when we shut down production in Alaska, we
weaken America's hand on the global stage. Every time the Federal
Government curtails the production of oil and gas in Alaska, it
strengthens the position of OPEC and our adversaries while undermining
America's geostrategic leverage, the very outcome Congress sought to
prevent by opening up the NPR-A in the first place.
The issuance of Biden's new highly restrictive IAP was widely
condemned as egregious by Alaskans. Our entire Alaska congressional
delegation slammed the decision as contrary to good science, in
contravention of congressional directives in Federal law, and foolish,
as the Biden administration implored OPEC+ members to produce more oil.
Alaska Governor Mike Dunleavy said the plan ``is another sign of the
federal government turning its back on Alaska and hampering domestic
energy production.'' The Arctic Slope Regional Corporation, ASRC, one
of the 12 land-owning Alaska Native corporations created under the 1971
Alaska Native Claims Settlement Act, ANCSA, and representing the
interests of more than 13,000 Inupiat shareholders, echoed those
concerns. In testimony before the Alaska Legislature, ASRC Vice
President of External Affairs Bridget Anderson explained, ``despite our
sustained efforts and our willingness to work with the federal
government, our perspectives are often drowned out by entities who have
no ties to our region nor have any understanding of the nuances of the
ANCSA model of indigenous representation. The choice by members of
Congress and the administration to overlook our voices is not only
frustrating, it is insulting.'' The Alaska Legislature passed a
resolution unopposed, sponsored by the legislator representing the
North Slope, an Inupiat himself, urging BLM to maximize the area
available for oil and gas leasing and development in the NPR-A and to
take into account the long history of safe and responsible oil and gas
development on the North Slope. All these Alaskan voices were ignored.
Importantly, my joint resolution is supported by the North Slope
Regional Trilateral, which is made up of the elected leaders of the
North Slope Borough, the Inupiat Community of the Arctic Slope, which
is the regional tribe, and ASRC. The members of the North Slope
Regional Trilateral voiced their opposition to the Biden
administration's overbearing restrictions during his 4 years in office.
Yet, despite their opposition, they were ignored--a repeated offense of
the Biden administration, who repeatedly disregarded Alaska Native
voices. In fact, North Slope leaders from my State flew thousands of
miles eight separate times to DC to request a meeting with Secretary of
the Interior Haaland to oppose her lock-up of the North Slope. Eight
times, she refused to meet with them. The Trilateral's letter of
support for the disapproval resolution notes that the 2022 IAP put in
place by the Biden administration imposes ``sweeping restrictions that
curtail responsible development, undermine congressional intent, and
disregard the well-being of the people who depend on these lands for
both subsistence and livelihoods'' and ``disregards the economic needs
of North Slope communities, and creates unnecessary obstacles to
infrastructure, energy, and community health across the North Slope of
Alaska.''
Fortunately, elections have consequences, and on his first day in
office of his second term, President Trump signed Executive Order
14153, ``Unleashing Alaska's Extraordinary Resource Potential,'' which
called for the rescission of the 2022 Integrated Activity Plan Record
of Decision and a reimplementation of the IAP issued by the first Trump
administration in 2020. This past summer, Secretary of the Interior
Doug Burgum flew to Alaska and held a townhall on the North Slope with
regional leaders and listened to their concerns, showing respect for
the Alaska Native people who live there. Under his leadership, he has
already advanced steps to rescind Biden's other disastrous restriction
on the NPR-A: the 2024 Management and Protection of the National
Petroleum Reserve in Alaska final rule.
In March of this year, Alaska's congressional delegation requested
that
[[Page S7999]]
the Government Accountability Office, GAO, determine whether the 2022
NPR-A IAP ROD constituted a ``rule'' under the Congressional Review
Act, CRA. GAO issued its legal opinion in July, concluding that the
2022 NPR-A IAP ROD is a rule under the Administrative Procedures Act
and subject to the CRA and congressional disapproval, the action we are
taking with S.J. Res. 80.
Further, this Congress has already taken decisive steps to unlock the
NPR-A. In the ``One Big Beautiful Bill Act,'' P.L. 119-21, Congress
mandated lease sales to be offered under the same terms and conditions
set forth in the 2020 IAP. Passage of S.J. Res. 80 would durably
protect against another rogue administration promulgating a
substantially similar anti-development management plan for the NPR-A as
contained in the 2022 IAP ROD.
In addition to the Trilateral, this resolution of disapproval is
supported by the Alaska Support Industry Alliance, the Alaska Oil and
Gas Association, the Resource Development Council for Alaska, Citizens
for Responsible Energy Solutions, the American Exploration and
Production Council, the National Federation of Independent Business,
the American Petroleum Institute, Americans for Prosperity, the Alaska
Chamber, as well as by the Trump administration.
I ask unanimous consent to have printed in the Congressional Record a
letter from the Resource Development Council for Alaska, dated October
30, 2025, expressing strong support for S.J. Res. 80 and H.J. Res. 124.
I urge my colleagues to reject unlawful regulatory overreach,
reinforce American energy dominance, uphold Federal law, and listen to
Alaska Native voices by supporting the Alaska congressional delegation
and voting for this joint resolution of disapproval and rescinding this
Record of Decision.
There being no objection, the material was ordered to be printed in
the Record, as follows:
Resource Development Council,
Anchorage, Alaska, October 30, 2025.
Re Support for S.J. Res. 80/H.J. Res. 124.
Hon. Senator Lisa Murkowski,
Washington, DC.
Hon. Congressman Nick Begich,
Washington, DC.
Hon. Senator Dan Sullivan,
Washington, DC.
Dear Senator Murkowski, Senator Sullivan, and Congressman
Begich: The Resource Development Council for Alaska (RDC)
writes in support of S.J. Res. 80 and H.J. Res. 124 to
disapprove the BLM's 2022 NPR-A Integrated Activity Plan
Record of Decision. RDC strongly supports these joint
resolutions and urges Congress's and the President's swift
action to reject this misguided and harmful pLanning
decision.
RDC is a statewide, non-profit trade association founded in
1975. Our membership is comprised of individuals and
companies from Alaska's fishing, tourism, forestry, mining,
and oil and gas industries and 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 23 million acres contained in the NPR-A were set aside
by the federal government in 1923, and directed by Congress
in the Naval Petroleum Reserves Act of 1976, specifically for
natural resource development, balanced with conservation, to
promote America's national security through energy resources,
and it is an asset to the State of Alaska. Responsible
development in the NPR-A supports our nation's energy
security, well-paying jobs and economic benefits for local
Alaska Native communities and the state as a whole. The 2022
BLM ROD improperly limits future oil and gas lease sales and
development to occur by creating a presumption against future
permitting. This is a bad policy that does not support Alaska
Native communities, organized labor, or our energy
independence.
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, RDC supports an IAP for NPR-A
that reopens all of NPR-A's subsurface historically available
to oil and gas leasing with reasonable and economically
feasible stipulations that do not discourage the development
and transport of energy resources.
The 2022 BLM IAP ROD unnecessarily prohibits leasing and
development of potentially oil-rich lands in much of the NPR-
A. This is a clear example of agency overreach and will only
discourage responsible resource development and America's
energy independence. As RDC has emphasized numerous times
before, the NPR-A is a petroleum reserve with a proven record
where surface resources and subsistence can be protected
without unduly restricting highly prospective areas to
leasing.
Decades of oil and gas activity on the North Slope clearly
demonstrate industry can operate in 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
everdecreasing 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
services. New industry activity will also provide thousands
of job opportunities, boost the local, state, and national
economy, and help refill the Trans-Alaska Pipeline System
(TAPS). Development of new energy deposits will also reduce
reliance on imported oil and help maintain American energy
dominance.
Given the NPR-A was specifically designated by Congress to
produce critical energy resources, it is important the BLM
continues to provide access to prospects with the highest
potential. That is why this SJR 80 and HJR 124 are so
critical to reverse the overreach of BLM's 2022 NPR-A IAP
record of decision.
RDC is concerned with the alarming trend from the last
administration of ``locking up'' oil-rich lands in NPR-A and
providing for less leasing and less access. Much of the most
prospective acreage could be removed from leasing under the
2022 ROD, including those closest to potential future
production. To much protest and lack of adequate
consultation, the BLM's 2022 IAP record of decision for the
NPR-A did just this--locking up highly prospective areas and
layering surface protections prohibitive to leasing or
development.
On a related note, attached to this letter of support is a
copy of RDC's comments to the 2023 BLM Proposed Rule for the
Management and Protection of the National Petroleum Reserve
in Alaska, 43 CFR Part 2360, RIN 1004-AE95, dated December 7,
2023. While this rule is currently under consideration for
rescission pursuant to Executive Order 14153 and Department
of Interior Secretarial Order 3422, related to ``Unleashing
Alaska's Extraordinary Resource Potential,'' (which RDC
fully supports) we hope these comments help you and your
staff with historical context for building support for
these CRA's to disapprove the BLM's 2022 NPR-A IAP record
of decision.
Conclusion
RDC appreciates your leadership introducing S.J. Res. 80
and H.J. Res. 124 and moving forward with disapproval of the
BLM's 2022 NPR-A IPA Record of Decision. The 2022 ROD went
too far and does not properly follow the intent and purpose
for the NPR-A and mandated by Congress.
A CRA disapproving the 2022 ROD for the NPR-A IAP will
ensure federal lands in Alaska are open for business and help
demonstrate energy dominance for the United States. The
ability to develop new energy deposits in NPR-A will benefit
Alaska, local communities, and the nation. Revenues derived
from new production will also help sustain important state
services. Industry activity will provide new job
opportunities for local residents and others while boosting
the economy. Increased access to NPR-A can be accommodated
without sacrificing the traditional ways of life, especially
the subsistence needs of Alaska residents in the Arctic.
Ensuring the NPR-A is open for future lease sales will
maintain America's energy dominance and reduce foreign
imports.
Thank you for your leadership on this issue of vital
importance to Alaska's economic future.
Sincerely,
Leila Kimbrell,
Executive Director.
____
Resource Development Council,
Anchorage, Alaska, December 7, 2023.
Re BLM Proposed Rule for the Management and Protection of the
National Petroleum Reserve in Alaska, 43 CFR Part 2360,
RIN 1004-AE95.
Department of Interior,
Director, Bureau of Land Management,
Washington, DC.
Dear Director: The Resource Development Council for Alaska,
Inc. (RDC) submits the following comments to the Bureau of
Land Management's (BLM) proposed rule for the ``Management
and Protection of the National Petroleum Reserve in Alaska
(NPR-A)'' originally published on September 8, 2023 (FR
62025). This proposed rule reflects a sea change to
management of the NPR-A as it was originally intended. The
rule is unnecessary, overly burdensome, fails to comply with
current law. For the reasons that follow, at a minimum, this
proposed rule should not be adopted.
Who We Are: The RDC is a statewide, not for profit, trade
association comprised of individuals and companies from
Alaska's fishing, tourism, forestry, mining, and oil and gas
industries. RDC's membership includes all the land-owning
Alaska Native regional corporations as well as village
corporations, local communities, including the North Slope
Borough, organized labor, and industry support firms. RDC's
purpose is to encourage
[[Page S8000]]
a strong, diversified private sector in Alaska and expand the
state's economic base through the responsible development of
our natural resources. The industries RDC represents are
historically significant economic drivers for Alaska's
economy. Combined, these industries employ or support
employment for the majority of the more than 730,000 Alaskans
who call Alaska home. For more than 48 years, RDC has proud
history of balancing the need for a diverse economy with the
need for the responsible development of our natural
resources. The proposed rule threatens to reverse that.
Comment Period Should Have Been Extended: The comment
period should be extended to allow for full participation of
all Alaskans, in particular, the communities of the North
Slope who are most impacted by this proposed rule. This
proposed rule was published on September 8, 2023, with an
original public comment period deadline of November 7, that
has since been extended twice to the current deadline of
December 7, 2023.
Notwithstanding these extensions, more time is needed to
assess and analyze the substantive and technical changes
proposed by this rule. The agency should not be rushing this
process that has the effect of creating a presumption against
oil and gas development in the NPR-A. RDC is not suggesting
environmental standards and protections should be reduced for
the Special Areas designated within the NPR-A. However, this
is a major change to the long established management program
for the NPR-A that needs sufficient time to assess impacts.
Further, it appears that the agency is trying to rush this
process through for its own political purposes, which is an
improper reason for fast-tracking such a major proposed rule.
It has been reported that a representative of the agency
stated during a public meeting that an extension of time was
not possible because the agency had to consider timing under
the Congressional Review Act (CRA). Using the CRA timeline to
avoid a possible reversal in the next congress is a political
maneuver that does not justify short circuiting the public
process.
Failed Consultation: The proposed rule spends considerable
time pointing to the importance of subsistence and the needs
for Alaska's Native peoples and the North Slope communities
who rely on subsistence hunting and fishing to justify this
proposed rule. RDC does not dispute that subsistence is an
important and critical practice for all Alaskans, including
Alaska Native peoples and their communities. However, despite
this focus, the BLM ignores the needs of our Alaska Native
peoples during this rulemaking process. BLM published this
proposed rule during a critical subsistence period for the
communities on Alaska's North Slope: the fall whaling season.
RDC has been told that little to no consultation has occurred
between the Alaska Native entities of the North Slope, the
North Slope Borough, and other key stakeholders. What little
consultation or public meeting process did occur was hastily
convened with little to no opportunity for local communities
to receive timely notice.
Although the proposed rule claims to comply with E.O.
13175, requiring consultatIon and coordination with Indian
Tribal Governments, including Alaska Native Tribes and ANCSA
Alaska Native Corporations, the record does not support that.
Sending one letter informing these stakeholders of a
rulemaking effort followed by a lack of adequate consultation
and doing so during an importance subsistence harvest period
without granting numerous extensions of time requests from
these same stakeholders fails to comply with the law and
department policy. The BLM Management should not fail in its
responsibility to consult with Alaska's federally recognized
Tribes and Alaska Native corporation. Meaningful consultation
is required by E.O. 13175 (November 6, 2000), POTUS Memo on
Tribal Consultation and Nation-to-Nation Building (January
26, 2021) and DOI 512 DM 4 (2015), and DOI 512 DM 5.
The Proposed Rule Exceeds BLM Authority: This proposal
creates a new, burdensome, and time-consuming administrative
process for reviewing oil and gas related development
activities that are contrary to the needs and purposes of the
NPR-A. The proposed rule takes the instruction of maximizing
protection of Special Areas under the federal NPR-A Act
(NPRAA) to an extreme that is not warranted and fails to
balance the need for oil and gas development to occur for the
nation's energy security and independence. BLM potentially
exceeds its authority by incorporating the Integrated
Activity Plan of 2022 (IAP) into the NPR-A regulations when
the NPR-A is specifically exempt from the Federal Land
Management Planning Act (FLPMA) planning requirement. BLM
acknowledges this in the proposed rule but goes onto to say
that it ``nonetheless'' intends to do so. In another example,
BLM proposes to change the authority of officers making oil
and gas related decisions from what currently must be
exercised consistent with current law and after consultation
with federal, state, local agencies and Native organizations
to now ``regardless of any existing authority.'' Agencies
cannot simply grant themselves the power to make decisions
``regardless of any existing authority;'' that is simply not
how our democratic process works. If anything, this proposed
change is less than clear and needs additional time for
review.
Presumption Against Oil & Gas Development Violates the
NPRAA: The proposed rule specifically explains, under section
2361.10, that BLM will now have the authority to delay or
deny, without setting a timetable, on any activities it
determines will have significant adverse effects on surface
resources. This is overly broad and restrictive. Further, the
proposed rule states it will ``presume . . . that that oil
and gas leasing or infrastructure on lands allocated as
available for such activities `should NOT be permitted' . .
.'' (Emphasis added.) This directly contravenes the purpose
and intent for which the NPR-A was established. The NPRAA
directed DOI to be administered for domestic energy
production through an oil and gas leasing program. BLM cannot
create a presumption by rulemaking that it will not permit
activity directed by Congress.
Further, the rule states it will not impact any current
leasing approvals or permitted activity. This is not true.
The proposed rule threatens harm to existing lease contracts
given its clear conflict with NPR-A's original purposes when
created in 1923 and as directed by Congress through the
NPRAA.
Flawed Economic Assessment: The proposed rule summarily
concludes it will not have a significant economic effect on a
substantial number of small entities under the Regulatory
Flexibility Act and only affects businesses in the oil and
gas industry operating in the NPR-A. This is simply wrong.
The DOI's analysis in support of the proposed rule did not
account for the significant economic benefits delivered to
local Alaska communities (including Alaska Native
organizations) from NPR-A development. Federal law mandates
that 50% of lease revenue from NPR-A projects go towards a
unique grant program that prioritizes improvement projects
that will deliver social and environmental justice benefits
to impacted communities, many of which are Alaska Native
communities. The economic analysis fails to consider the
impact of local communities losing these benefits. The
economic analysis also wholly fails to consider the social
implications of eliminating or dramatically restricting
future development in the NPR-A that would remove jobs and a
substantial portion of the tax base. Responsible development
on the NPR-A creates enormous economic benefits. The
economic analysis the DOI used ignores benefits like the
NPR-A Impact Mitigation Grant program. This grant program
creates a legal requirement for local communities to
receive generous revenues from projects. If project
development is slowed or halted by the new rule, Alaska
Native communities will lose enormous revenues for public
services, health facilities and educational resources--to
name a few impacted areas.
Further, the proposed rule will stifle any future
development in currently approved areas of the NPR-A as
companies will be wary to invest into developments in areas
where the government can seemingly outlaw further development
without cause. This chilling effect will have a dramatic
economic impact.
Alaska's North Slope (ANS) energy production and
infrastructure has had significant economic impact and
contribution to Alaska's economy and our nation's energy
security. In 2022, ANS produced an average of 482,000 bpd.
Since the Trans Alaska Pipeline Systems (TAPS) was created,
ANS has produced over 18.5 billion barrels of oil. In 2022,
this support 69,250 jobs in Alaska, or 16% of employment in
Alaska and accounting for $5.9 billion in wages, or 17% of
wages in Alaska. Alaska's oil and gas industry contributed
$4.5 billion in revenue to state and local governments,
comprising 47% of state revenue in 2022. Over time, since
statehood in 1959, the oil and gas industry has produced $274
billion in petroleum revenues to the State. This is a
significant economic impact that is threatened by this
proposed rule if implemented.
Failed Unfunded Mandates Reform Act Assessment: Similarly,
the proposed rule concludes without explanation that it would
not have a significant or unique effect on State, local, or
Tribal governments. This is also simply false. Diminished oil
production from the NPR-A would result in diminished
production tax and ad valorem tax revenue for the State and
local governments in Alaska. This means less revenue for the
State of Alaska to provide services to all Alaskans. The
BLM's reasoning in this regard also likely violates its
conclusion that this does not have federalism implications
under E.O. 13132.
The Proposed Rule is a Direct Threat to America's Energy
Security: The proposed rule concludes it will not adversely
affect our national energy security in contravention of E.O.
13211. In almost the same breath, the agency states the
proposed rule will ``presume . . . that that oil and gas
leasing or infrastructure on lands allocated as available for
such activities `should NOT be permitted'. . ..'' (Emphasis
added.) There is no way to explain the logic of this
assessment. A presumption against approving oil and gas
leasing absolutely equates to less development of oil and gas
energy resources.
Analysis from the U.S. Geological Survey estimates there
are 8.7 billion barrels of undiscovered oil in the NPR-A, an
area set aside by the Federal government specifically for
petroleum development. By denying or dramatically restricting
development in the region, the Administration is denying
Alaskans--and all Americans--reliable, affordable energy, as
well as billions of dollars in revenues. We cannot afford to
further limit U.S. production which will only increase our
reliance on foreign nations, including adversarial nations,
amid rising geopolitical
[[Page S8001]]
threats. At a time when oil prices are rising and global
supply can be easily constricted by foreign governments,
investing in domestic oil production is a matter of national
and energy security. During a time of high inflation across
the country, this misguided rule will almost certainly lead
to higher energy prices for working class families across
America. Restricting access to energy development limits
consumers' access to affordable, reliable energy.
Furthermore, oil production on the North Slope and in the
NPR-A contributes to the Trans-Alaska Pipeline System (TAPS),
a vital piece of U.S. infrastructure. Oil produced in the
NPR-A will keep TAPS economically viable and capable of
providing oil to the rest of the United States and beyond.
Restricting future development of the NPR-A by creating a
presumption against permitting the uses for which the NPR-A
was specifically developed directly threatens our energy
security.
Conclusion: As indicated above, this process is being fast-
tracked, lacks transparency, possibly exceeds the agency's
legal authority, and lacks proper consultation as required by
department policy. At the very least, the complexity of the
new proposal warrants additional time for public review and
scrutiny and, importantly, meaningful consultation with the
Alaska Native tribal entities, corporations, and communities
most impacted by these decisions.
Thank you for your consideration of these comments.
Sincerely,
Leila Kimbrell,
Executive Director.
____________________