Letter to David Bernhardt, Secretary of the Interior - Congressman Lowenthal, Natural Resources Committee Leadership, Call on Administration to Suspend Action On Massive Alaskan Oil Development Plan

Letter

Dear Secretary Bernhardt:

We urge you to suspend any further action on the Willow Master Development Plan (Willow
Plan) Supplemental Draft Environmental Impact Statement (SDEIS). We are greatly concerned
by the harmful impacts that this development could have on the unique ecological and
subsistence values found in the National Petroleum Reserve -- Alaska (Reserve). Interior's
actions to move this, and other projects, forward during the COVID-19 crisis are contrary to the
National Environmental Policy Act's mandate for public involvement. This is particularly true
for the Willow Plan, which would significantly impact rural Alaska Native communities that
have limited access to reliable high-speed internet, or other required forms of technology,
necessary to be able to meaningfully participate in the process.

It is unacceptable for the Bureau of Land Management (BLM) to move forward with the Willow
Plan public comment periods, public meetings, and subsistence hearings in the middle of a global
pandemic that is especially dangerous to rural Alaska communities. The recent attempt at a
virtual public meeting for North Slope residents was plagued by technological glitches and
bandwidth constraints, and is in no way an acceptable substitute for an in-person meeting,
particularly given the limited amount of high-speed internet connectivity and other necessary
technology in the remote areas of Alaska where the people impacted by this proposal live. It is
also unconscionable to request people currently focused on and concerned with the health and
wellbeing of their families and communities to refocus their concern toward the complexities of
a project like the Willow Plan, which itself will have significant effects on local people and
resources. BLM has already lost a court case by failing to provide adequate public comment
opportunities for oil and gas projects, and we believe your action with the SDEIS could face
similar legal risk.

BLM has failed to recognize the cumulative infrastructure and development impacts
ConocoPhillips' oil and gas project will have on the region. Neither the draft EIS nor the SDEIS
is sufficient to fulfill BLM's NEPA requirement to consider a reasonable range of alternatives.
Furthermore, the SDEIS fails to consider any alternatives that are protective of sensitive
resources in the region. BLM should be maintaining the strongest possible protections for
Special Areas within the Reserve. Instead, the proposed Willow Plan development encroaches
into the Colville River and Teshekpuk Lake Special Areas. The proposed gravel mines would be
adjacent to the Colville River Special Area, with a proposed gravel road and pipeline routing
through the Special Area. The proposed oil and gas infrastructure and industrial activities will
also extend into Teshekpuk Lake Special Area, an area that has been protected for decades
because of its ecological value as the largest Arctic lake. Permanent infrastructure from this
development will impact critical nesting areas for endangered bird species as well as high
density, year-round range for the Teshekpuk Caribou Herd, causing lasting impacts to wildlife.

Rural communities on the North Slope rely upon subsistence resources like the Teshekpuk
Caribou Herd, and threats to the health of these resources are threats to the traditional lifestyle of these communities. The proximity of the project to the community of Nuiqsut and its potential
adverse impacts on subsistence resources and cultural activities are gravely concerning. Existing
oil and gas projects have already degraded the region's air, water, and wildlife habitat. Continued
industrialization of the Arctic will further disrupt traditional hunting and cultural activities.

The Willow Plan is a continuation of efforts by the Trump administration to advance its
aggressive oil and gas development agenda, ignoring the public health, environmental,
subsistence, and climate impacts these projects will have. The Administration's efforts for the
Willow Plan are particularly egregious given the encroachment into the protected Special Areas,
impact on subsistence resources, and the inadequate public outreach efforts during the COVID19 crisis, which is effectively silencing Alaska Native voices by providing inadequate
opportunities for public participation by the impacted communities in the process.

The Willow Master Development Plan will result in the loss of irreplaceable ecological and
cultural values in America's Arctic. Now is not the time to be fast tracking permitting for a
massive new oil development project. We urge BLM to focus on maintaining strong protections
for Special Areas within the Reserve and not open additional acreage to new oil and gas projects.