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1987

of oil with an average or mean estimate of 13.8 billion barrels in place. Estimate of "recoverable" reserves ranges from 600 million barrels to 9.2 billion barrels with an average or mean estimate of 3.2 billion barrels. Draft report recommends full, but staged, leasing of coastal plain for oil and gas exploration and development, with caribou calving areas in the southern Jago River area to be leased last.

Lisburne oil field on the North Slope begins
production.

Public hearings held in early January in Kaktovik,
Anchorage and Washington, D.C. on Department of the
Interior's Draft Report and LEIS.

On January 6 Congressman Udall introduces H. R. 39, a bill to designate the 1.5 million acre coastal plain as a Wilderness area.

State of Alaska releases geophysical report on
coastal plain which contains similar, but slightly
more modest projections than those compiled by the
Department of the Interior on the coastal plain's oil
and gas potential.

On February 2, Oil & Gas Journal article on coastal
plain, notes "unconfirmed reports of good oil shows"
in Kaktovik exploratory well, and quotes industry
officials on "enormous potential" of coastal plain
study area and potential "opportunity of
participating in some billion barrel oil fields".

On February 11 Congressman Young introduces
H.R. 1082,, a bill to authorize competitive leasing,
exploration and development of the oil and gas
resources of the coastal plain in a manner consistent
with protection of the area's environment, fish and
wildlife resources and the needs of subsistence
users.

On February 24 the National Petroleum Council, transmits report to the Secretary of Energy on Factors Affecting U.S. Oil & Gas Outlook. Report concludes that crude oil imports could rise from 27 percent in 1985 to 50 percent by 1990 and to 60 percent by 1995.

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State of Alaska schedules lease sale in June 1987 for Camden Bay in State waters immediately north of and directly adjacent to the coastal plain.

On March 5 the 5 billionth barrel of crude oil is produced from the 600 development wells on the Prudhoe Bay reservoir.

National Wildlife Federation releases report on March 12 calling for a two-year national commission to further study the coastal plain. Report includes independent geologic study by Tom Marshall, former Alaska State Geologist who was instrumental in State's selection of Prudhoe Bay lands. Marshall's report concludes that Interior Departments study is very professional, but also very conservative in its oil and gas projections; and that coastal plain's hydrocarbon resource greatly exceeds the projections previously made by the Interior Department and the State of Alaska.

On April 20 the Department of the Interior releases final report and LEIS on Coastal Plain Resource Assessment. Secretary of Interior recommends full leasing alternative for coastal plain study area to the Congress.

In June the tenth year of operation of the TransAlaska Pipeline is observed in ceremonies in Alaska.

On May 15, S. 1217, a bill to authorize oil and gas leasing on the coastal plain, subject to proper environmental regulations and stipulations, is introduced by Senators Murkowski and Stevens.

On July 23, Department of the Interior announces agreement has been reached on terms to govern a major land exchange between six Native entities and the Department. Native entities would exchange 891,000 acres of Wildlife Refuge inholdings in Alaska for oil and gas interests in 166,000 acres of coastal plain. Department states land exchange will be subject to Congressional review and consummation will require express Congressional approval by Act of Congress. On August 3, the House of Representatives passes H.R. 2629, a bill to deal with legal questions and uncertainties concerning submerged lands in Alaska. Title II of bill contains the Bradley-Miller amendment to require that any land exchanges or conveyances within the coastal plain study area are approved by prior Act of Congress.

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The State of Alaska appreciates this opportunity to respond to questions raised by the Senate Energy and Natural Resources Committee regarding the Arctic National Wildlife Refuge (ANWR). The state strongly supports the conclusion of the Final 1002 Report that oil and gas exploration be allowed in ANWR consistent with the chief purpose of the refuge to preserve its unique wildlife values.

Congress must set high standards for environmental protection in ANWR, and can take several actions to ensure that this occurs. A comprehensive and specific set of environmental protection standards should be developed and applied to oil and gas activities in the refuge to ensure protection of air and water quality and fish and wildlife resources. The purposes for which ANWR was established must be recognized in developing the appropriate standards.

STATE RECOMMENDATIONS REGARDING MITIGATION

The state recommends that Congress include provisions in the ANWR legislation which:

1. incorporate the mitigation measures contained in the Final 1002 Report, as amended by the suggestions in Enclosure A of this letter;

2. incorporate into legislation a clear standard requiring the proper degree of environmental protection in the refuge;

3. provide adequate protection of the wildlife resources of the refuge;

4. require an advance planning process for development to address such issues as the proper management of all waste streams (e.g., emissions of NO industrial wastewater discharges, domestic wastewater discharges, drilling wastes,

The Honorable J. Bennett Johnston

November 10, 1987

Page 2

oil wastes, sludges, hazardous wastes, scrap metal, and
putrescrible wastes);

5. establish a process for interagency coordination in the development and refinement of detailed stipulations for all phases of oil and gas activities; and

6. require careful monitoring of compliance and environmental effects.

These recommendations are especially important given the lack of attention in the 1002 report to air and water quality and other environmental protection issues. The following is a more detailed discussion of these specific recommendations. Incorporate Final 1002 Mitigation Measures into Legislation

The state provided recommendations to the Department of the Interior (DOI) in a letter from Robert Grogan, Director, Division of Governmental Coordination, to Robert Gilmore, Regional Director, U.S. Fish and Wildlife Service (USFWS), on February 6, 1987, regarding mitigation measures that should be included in the Final 1002 Report. The DOI has already addressed some of the state's comments on the draft mitigation measures. At your request, the state has evaluated the mitigation measures contained in the final report and provided our observations in Enclosure A. The state is reiterating those comments which were not addressed in the final report and suggesting specific language for some stipulations which would resolve our concerns. The State of Alaska supports inclusion in legislation of the mitigation measures contained in the Final 1002 Report, with the language changes recommended in Enclosure A. While this does not represent a comprehensive mitigation package for ANWR exploration and development, it does provide a basic structure for the issues that need to be addressed. Legislation must also provide a strong environmental standard and process, as outlined in our comments below, that will allow for subsequent development of detailed stipulations to address additional environmental quality issues. The state recommends that the ability to modify or add to the stipulations be provided for in legislation. This will provide the necessary flexibility to modify the stipulations, as necessary, to reflect changes in technology, results of further research, or regulatory or statutory changes. Any changes to the legislated stipulations should be made only with concurrence of the State of Alaska, and with ample opportunities for public hotice and comment. This is especially important to the villages of Kaktovik, Nuiqsut, and Arctic Village since they rely heavily on the resources of the refuge for subsistence. A role for Congress may also be appropriate.

Develop Standards for Environmental Protection

The Honorable J. Bennett Johnston
November 10, 1987
Page 3

Legislation should require that a comprehensive and specific set of environmental standards be developed and applied to oil and gas activity in the refuge to ensure protection of air and water quality and fish and wildlife resources and uses. The mitigation measures contained in the Final 1002 Report do not address the full range of environmental quality issues in ANWR. The following issues of major importance have not been addressed:

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Development of clear standards to address these and other environmental quality considerations will require substantial additional effort, since little attention was formally paid to these issues in the Final 1002 Report. Legislation should require that specific mitigation measures be developed to address these issues. Legislation should also provide a role for environmental regulatory agencies in developing and interpreting these measures to ensure that appropriate technical expertise is available.

The mitigation measures which are developed must be based on a careful and critical evaluation of the experience and information gained regarding North Slope development. Key areas where improvements need to be considered include the management and disposal of drilling wastes, solid waste, hazardous wastes, oil waste, material site development and rehabilitation, cross drainage and fish passage, causeways, and produced fluids and gas.

Provide for Wildlife Protection

The State of Alaska recommends that Congress defer for ten years oil and gas leasing in the "core" caribou calving area (242,000 acres) described by the USFWS in the Draft 1002 Report. During this period, a seven-year research program should be undertaken to improve understanding of the importance of this core calving area, to assess the effects that oil development may have on use of the area, and to develop appropriate mitigation measures. The objective of this approach is to ensure the viability of the Porcupine Caribou Herd. There may be other ways to achieve this objective, and the state remains open to other options which would foster exploration and development of the oil and gas potential of the coastal plain while protecting the Porcupine Caribou Herd.

Require Pre-Development Planning

Legislation should require that explicit plans which address fish and wildlife protection and air and water quality issues be developed. For example, plans for management of major waste

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