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Providing coverage of Alaska and northern Canada's oil and gas industry
January 2021

Vol. 26, No4 Week of January 24, 2021

BOEM issues draft EIS for Cook Inlet sale

Area identified for proposed October OCS sale is 224 blocks in northern portion of planning area, same area offered in last sale

Kristen Nelson

Petroleum News

The U.S. Department of the Interior’s Bureau of Ocean Energy Management said Jan. 13 that the area to be considered for leasing in proposed 2021 OCS Cook Inlet lease sale 258, tentatively scheduled for Oct. 20, is 224 blocks toward the northern part of the inlet, some 1.09 million acres, from Kalgin Island in the north to Augustine Island in the south.

BOEM released a draft environmental impact statement for the sale on Jan. 15, with a 45-day public comment period on the draft EIS closing March 1. The agency said it will provide more information, including instructions for commenting via a virtual meeting room at www.boem.gov/CookInlet2021, with three virtual meetings to be held Feb. 9 from 2-4 p.m., Feb. 10 from 6:30-8:30 p.m. and Feb. 11 from 2-4 p.m., all Alaska time.

Deferred areas

In the Federal Register notice for the DEIS, BOEM said certain areas were deferred from consideration “due to potential conflicts with resources of high ecological and subsistence value.”

The majority of the area designated as critical habitat for beluga whale and northern sea otter is deferred, along with all of the critical habitat for Stellar sea lions and the North Pacific right whale. Some of these are in the planning area for the sale, which extends much farther south than the proposed sale, to the southern end of Kodiak Island.

Areas are also deferred creating a buffer between the proposed leasing area and the Katmai National Park and Preserve, the Kodiak National Wildlife Refuge and the Alaska Maritime National Wildlife Refuge.

Also deferred are “many of the subsistence use areas for the Native Villages of Nanwalek, Seldovia, and Port Graham,” identified in the process for an earlier Cook Inlet sale.

The most recent BOEM Cook Inlet sale, Sale 244, was held June 21, 2017, with 224 blocks offered, some 1.09 million acres. BOEM said it received 14 bids on 14 tracts, more than $3 million in high bids.

“The LS 244 offered the same area recommended here for proposed LS 258,” BOEM said in its area identification recommendation.

Sale 244 was part of the 2012-17 National OCS Program.

The 2017-22 National OCS Program, which includes LS 258, was approved in January 2017.

Comments

BOEM issued a call for comments in September and got responses from the State of Alaska and the Seldovia Village Tribe, a federally recognized tribe near the southern boundary of the Cook Inlet program area.

The state encouraged the agency to hold lease sale 258 as an areawide sale, which is how the state offers its major areas for lease, a request similar to that it made during development of the 2017-22 National Program.

But BOEM said the 2017-22 program “introduced a targeted leasing model to the Alaska OCS lease sale process,” the goal of which “is to focus oil and gas leasing on the most promising OCS blocks, while protecting important habitats and critical subsistence activities. The result is an area that is more geographically limited in scope and that eliminates many areas of environmental concern.”

Seldovia Village Tribe requested exclusion of blocks that overlap designated critical habitat for Cook Inlet beluga whale and northern sea otter, and BOEM said those proposed exclusions “helped inform the range of alternatives” for the proposed sale.

Proposed action

BOEM’s proposed action, alternative 1, would offer all leases available in northern portions of the planning area, some 1.09 million acres, 224 blocks, approximately 20% of the total planning area.

BOEM said because of targeted leasing, the proposed sale area:

*Focuses on areas closer to existing infrastructure.

*Focuses on areas closer to active OCS and state oil and gas leases.

*Avoids “the vast majority” of areas designated as beluga whale and northern sea otter critical habitat.

*Avoids completely Steller sea lion critical habitat.

*Reduces effects to national parks, preserves and wildlife refuges.

*Excludes much of subsistence use area for Alaska Native villages of Nanwalek and Port Graham identified in 2004.

Other alternatives

The no action alternative, alternative 2, would result in no lease sale being held.

Alternatives 3A, 3B and 3C address potential impacts to distinct population segments of the beluga whale in Cook Inlet. 3A would exclude the 10 OCS blocks overlapping beluga whale critical habitat at the northern tip of the proposed sale area, 29,373 acres. 3B would offer all available blocks in the proposed sale area, but no on-lease seismic surveys or exploration drilling would be allowed on the 10 northern blocks between Nov. 1 and April 1 when beluga are most likely to be present. 3C would offer all blocks in the proposed area, with seasonal mitigation to protect belugas, with certain seasonal mitigations applied to all OCS blocks between Nov. 1 and April 1; and additional seasonal mitigation applied to 146 OCS blocks wholly or partially within 10 miles of major anadromous streams.

Alternatives 4A and 4B address northern sea otter critical habitat; 4A would exclude seven blocks overlapping northern sea otter critical habitat, 29,388 acres. 4B would offer all available blocks but with additional mitigation on 14 blocks within 1,000 meters of northern sea otter critical habitat.

Under Alternative 5 all blocks would be offered, but with additional mitigation in all blocks north of Anchor Point to reduce potential for conflicts with the Cook Inlet drift gillnet fishery affecting all or parts of 117 OCS blocks, 503,927 acres. No on-lease seismic surveys would be allowed during the drift gillnetting season and United Cook Inlet Drift Association would have to be notified of any temporary or permanent structures planned during the drift gillnetting season. Alternative 5 is all blocks, partial or whole, north of Anchor Point.

Alternatives not analyzed

A number of alternatives were dismissed without detailed analysis.

A prohibition of drilling discharges was analyzed in detail for the 2017 sale, BOEM said, and the agency determined then “that the minimal decrease in environmental effects associated with the alternative was offset by an increase in impacts associated with barging muds and cuttings to shore.” In addition, the agency said, discharges of muds and cuttings are regulated by the Environmental Protection Agency through the National Pollutant Discharge Elimination System, which “allows such discharges only if they would not cause unreasonable degradation of the marine environment.”

A requirement for directional drilling from shore was suggested during scoping meetings, BOEM said, a method used at the Cosmopolitan unit north of Anchor Point. It said directional drilling could be considered as part of the National Environmental Policy Act evaluation for a specific plan, but said “it is not feasible as a lease sale alternative here where the vast majority of the Proposed Lease Sale Area is beyond the limit of directional drilling technology and geologic conditions are not necessarily conducive to safe and effective directional drilling.” The technology has a limit of some 7.6 miles, the agency said, but that was achieved at Sakhalin, which has different geology. “Wells of this nature could be very high risk in Cook Inlet due to the highly complex nature of the geology and the presence of coal seams that could squeeze (flow) into the wellbore trapping the drill stem,” BOEM said. All the OCS blocks are at least 3 miles from shore and only 20.42% of the proposed area is within 7.6 miles from shore. Because 80% of the blocks would not be reachable, directional drilling would not meet the purpose and need for the proposed action.

Another alternative which was not analyzed would prohibit any seismic surveys when migrating salmon are present. This was suggested during scoping. BOEM said the goal of targeted leasing is to identify areas with high resource potential and indications of industry interest, “while appropriately weighing environmental protection and subsistence use needs.”

The agency said peak salmon abundance in Cook Inlet is from June through August when “migrating aggregations occur nearshore and in freshwater streams” - areas outside the lease sale area. Since salmon are prey for beluga whales, an alternative proposed for beluga protection would also extend to migrating salmon, making the suggested alternative duplicative of an existing alternative.

An alternative to prohibit exploration or drilling activities from June to September when waters outside Cook Inlet in the Gulf of Alaska are important for right whales was suggested during scoping. North Pacific right whales and right whale critical habitat are outside the area of the proposed sale, BOEM said, and it determined “additional exploration activity restrictions based on considerations for North Pacific right whales were not warranted and the alternative was not analyzed in detail.”

An alternative to exclude all OCS blocks north of Anchor Point was recommended in scoping. BOEM said that would remove 117 OCS blocks and reduce the proposed area for the sale by 503,928 acres, 46.05%. The objective was to reduce potential for interaction with the drift gillnet fishery and interaction with beluga whales, but the agency said it determined this alternative would not meet the purpose and need of the sale due to relatively high industry interest in the area and that the goals of the alternative are addressed by the proposed action and measures proposed under alternatives 3A, 3B and 3C, as well as Alternative 5.

A lower Kenai Peninsula exclusion in an earlier lease sale consisted of 34 whole or partial OCS blocks off Port Graham, Nanwalek, Seldovia and the tip of the lower Kenai Peninsula. BOEM said most of this area had already been excluded through the area identification process and target leasing, with only nine of the OCS blocks in the former exclusion within the proposed lease sale area.

The agency said subsistence uses in OCS waters off the lower Kenai Peninsula “are inherently seasonal and BOEM expects that potential conflicts can be avoided through other mitigation included in the Proposed Action,” and therefore a lower Kenai Peninsula exclusion was not evaluated in detail for this EIS.





BOEM exploration, development scenarios

In its draft environmental impact statement for lease sale 258 in Cook Inlet, the Bureau of Ocean Energy Management looks at exploration and development scenarios for oil and gas that might be found on blocks in the lease sale area. The agency notes that, unlike other Alaska outer continental shelf planning areas, Cook Inlet “has a nearby market for both oil and gas. As a result, the current Cook Inlet E&D scenario does not defer gas sales until oil production is depleted.”

There is an existing natural gas distribution system in Cook Inlet which “could be extended to transport gas from the Cook Inlet OCS to the greater Anchorage and Kenai Peninsula areas.”

Federal lease sales have been held in Cook Inlet since 1977 and four exploration wells have been drilled in the current lease sale area as a result of sales in 1977 and 1981, BOEM said.

“None of the four exploration wells discovered oil or natural gas in economic quantities and the last exploration well drilled was plugged and abandoned in 1984,” after testing prospects which, given knowledge at the time, were believed to have the best prospects for large volumes of oil and gas.

In the current exploration and development scenario, the high activity case estimates that eight exploration and delineation wells would be drilled over a 3-year period.

BOEM said its geoscientists and engineers believe Tertiary oil and gas plays will be the main attraction within the proposed lease area “because of their proven petroleum potential in the northern part of the Cook Inlet Basin and their past performance in hosting commercial oil and gas fields.”

The range of activities estimated for low, medium and high activity levels includes a low case where one natural gas field is discovered and developed; a medium case based on one oil field discovered and developed with associated natural gas which would also be produced; a high case with both fields in the low and medium case discovered and developed.

In the high case, a maximum of four 24-slot platforms would be required, with 65 wells — production and service — drilled.

Seismic and geohazard surveys are assumed in the analyses.

Mobile offshore drilling units, MODU, would be employed for exploration drilling, and BOEM said it estimated that three wells per drilling rig could be drilled, tested, plugged and abandoned during a season. The assumption is that only one MODU would be used, BOEM said, noting that “historically there has only been one MODU working in the proposed lease sale area at one time,” although as of December there are two MODUs in Cook Inlet both out of service.

Following delineation drilling, permitting would occur for development, with submission of a development and production plan.

If there are multiple platforms, the first would serve “as a hub, connecting pipelines from other platforms to the main pipelines to shore,” BOEM said.

Subsea pipelines are the preferred method to transport oil and gas to shore from a platform, with the nearest landfall location “likely on the southern Kenai Peninsula near either Homer or Nikiski, depending upon where the first commercial oil discover is located.”

Because of the location of existing pipelines in upper Cook Inlet, “it is not anticipated that any of the production platforms from new discoveries in lower Cook Inlet will be able to utilize any existing pipelines,” the agency said.

Because of Cook Inlet’s history of oil and gas production from offshore state leases, BOEM said it assumed that existing onshore infrastructure has capacity to support OCS exploration and development without major expansion or modification.

The exploration drilling timespan is estimated at 3 years, followed by a 3-year environmental analysis process between delineation and development.

The time needed to install platforms and drill wells after discovery is the main driver of the development and production phase, with 7 years estimated to install four production platforms in the event separate oil and gas fields are discovered and developed, Wbased on a construction estimate of 3 years for a platform before installation.

“Each platform is installed, commissioned, and producing in its first year of operation,” BOEM said. Wells are assumed to have an average economic life expectancy of about 20 years, and if first wells begin production 7 years after discovery, and last development wells drilled in year 14, decommissioning would begin after year 34.

—KRISTEN NELSON


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