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BLM: Good plan analysis best protection US Fish & Wildlife Service, EPA, State of Alaska, North Slope Borough all cooperating agencies in new NPR-A planning process Kristen Nelson Petroleum News
Bringing on production from the National Petroleum Reserve-Alaska is not up to the Bureau of Land Management, Julia Dougan, BLM’s acting Alaska state director, told a Resource Development Council breakfast Oct. 31.
Dougan, whose presentation to the group was on BLM’s work on a new plan for NPR-A — public comments as part of the scoping process closed the next day — got a lot of questions on why, as one audience member put it, there is no production from NPR-A after 60 years of exploration.
The federal government began exploring in NPR-A after World War II and after the current leasing program began in 1999, more than two dozen wells have been drilled by five companies. There are currently some 2.39 million acres under lease in NPR-A to seven companies.
“The BLM’s job is to make lands available through leasing,” Dougan said. “It’s industry role to determine the pace and scope of that development, but I think that has to be done in some sort of partnership.”
She said she’d like to hear from industry about why it’s taken so long, but said she could speculate and thinks “lack of infrastructure probably is one thing” holding up development.
“But that’s really up to industry to drive the pace of development,” Dougan said.
What needs to be analyzed? She said if industry identified barriers to development, BLM could analyze them in the scoping process.
Asked if the plan BLM is developing for NPR-A would include things that would not only assure leasing but also development, Dougan said that’s what BLM needs to know.
“What should we analyze in this plan that would allow development to occur? Should we analyze, for example some … adjacent infrastructure that would allow development to move into NPR-A,” she asked.
“It’s difficult to start analyzing things that are under someone else’s jurisdiction — but yet we know it’s critical to the development of NPR-A.”
She also said she that in her opinion “one of the biggest disincentives … is uncertainty.”
While BLM can’t promise that the new plan will be in place forever, “We want to do as much as we can to provide as much certainty as possible,” Dougan said.
Corridors can’t be designated Asked if BLM had the authority to designate transportation corridors or areas where infrastructure could be built, Dougan said BLM had heard a lot about the road, pipeline and infrastructure issue in scoping meetings, including the issue of pipeline which might be proposed to carry offshore oil and gas across NPR-A to the trans-Alaska oil pipeline.
She said she wouldn’t want to pick road or facility locations, because any she picked might not work for a company’s development.
“But what we can do, is as much as possible clearly identify those areas where it would not be appropriate to have some of those facilities,” she said.
That, she said, would provide industry with some sense of where facilities could be planned.
The litigation issue Asked what BLM could do to limit litigation, Dougan said BLM can limit litigation “by doing a really comprehensive job in our planning.” She said litigation is over BLM’s compliance with the National Environmental Policy Act.
Courts look at whether BLM followed the process and if the agency did what it should have done.
“Not did we make the right decision, but did we follow the process,” Dougan said.
She said cumulative impact assessments and climate change are probably the most challenging issues.
On cumulative impacts the issue is where do you stop: “We’re now going to look at onshore-offshore; we’re going to look at future infrastructure,” Dougan said.
In previous planning efforts, “we have been sustained on our approach when we have been litigated,” she said.
“Our job is to analyze and disclose the impacts to the best degree we can; and we’ll be upheld when we do that.”
The consultation issue In a reference to the refusal by the U.S. Army Corps of Engineers to permit a bridge across the Nigliq Channel of the Colville River for access to a proposed CD-5 drilling pad in NPR-A, Dougan was asked about consulting with the Corps, the Environmental Protection Agency and the U.S. Fish and Wildlife Service in the planning stage.
Dougan said federal planning includes a process called cooperating agencies, where federal and state agencies are invited to join the planning effort. She said the term is a little misleading because cooperating doesn’t mean an agency is in agreement with what BLM wants to do, just that they’ll cooperate in the planning process.
Fish and Wildlife has agreed to be a cooperating agency, as has the Bureau of Ocean Energy Management, Regulation and Enforcement (the old Minerals Management Service), the State of Alaska and the North Slope Borough.
“And that’s really a significant obligation they’ve taken on, because they get to be at the table as we formulate alternatives and do analysis.”
While the Corps of Engineers didn’t choose to be a cooperating agency, Dougan said BLM will work and coordinate with them.
“We know that’s in our best interests and in everyone else’s best interest, because of all the … permitting that’s outside the BLM’s jurisdiction,” she said.
Dougan said BLM wants to do as much analysis of impacts in the plan as possible so other agencies don’t have to do repetitive work. BLM intends to work closely with other agencies, Dougan said, “because we certainly know nothing can move forward without those agencies.”
Aggressive schedule Dougan said BLM is doing a new planning effort because NPR-A was originally divided into three sections, northeast, northwest and south. Plans have been done for the northeast and northwest, but the plan for the south was never completed.
The existing plans, she said, were done over several years and “left us with a patchwork of decisions, stipulations and mitigations that don’t really mesh and aren’t consistent across NPR-A.”
BLM believes a new plan will result in “a consistent ongoing leasing program with consistent stipulations and requirements.”
And things have changed since the existing plans were done.
BLM now needs to look at the “offshore-onshore interface” as offshore exploration moves closer.
While it hasn’t happened yet, it is “far less than speculative,” and oil found offshore would most likely be brought to shore and moved to the trans-Alaska oil pipeline through a pipeline across NPR-A.
The natural gas pipeline has also moved out of the speculative stage, she said, “so now we really need to look at that also because of the potential for gas in NPR-A.”
Plans for a road to Umiat are also moving along and BLM needs to look at what that means for NPR-A, Dougan said.
Because of those changes, BLM has been left “with planning documents that you could say might be open to a legal challenge, so we want to make sure we have the most robust, sound documents we could have,” she said.
Scoping started in July and BLM anticipates having a draft plan out in January of 2012, with a record of decision on the plan in October of 2012.
“That’s a very aggressive planning schedule,” Dougan said.
NPR-A is 22 million acres, “the largest contiguous piece of public lands in the United States, so this planning effort will be the largest planning effort undertaken by … any public federal land management agency in the country,” she said.
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