believes a new Pikka or Willow discovery might be made. Armstrong must be taken seriously because his company led the exploration that led to the Pikka find along with other North Slope discoveries. The NPR-A land management rule put in place in June is already the subject of multiple lawsuits. “This undermines the intent of Congress, which has long designated the NPR-A as a critical area for oil and gas production to support Alaska’s economy and the nation’s energy security,” AOGA CEO Moriarty wrote in mid-September a letter to the BLM. “The RFI (request for information on protected areas) represents another step toward implementing the rule that disregards this intent, jeopardizing the balance between responsible development and conservation in the NPR-A,” Moriarty wrote. There is no need to modify the protected Special Areas at this time. The new rule allows reconsideration of these every 10 years. BLM claims the last evaluation was in the Integrated Activity Plan for the reserve approved in 2013, Moriarty said, But in a 2020 Integrated Activity Plan the BLM reviewed all five Special Areas and made changes in three of them, she said. In 2022 the BLM reassessed the IAP and confirmed that it was still adequate. AOGA is also concerned about the lack of transparency in the new call for comments. “Instead of establishing a publicly accessible outreach docket, BLM has asked for comments to be submitted by email, a private format which diminishes the transparency of stakeholder engagement,” Moriarty said. “The current RFI process, with its limited visibility and lack of transparency, runs contrary to the practices BLM has historically followed,” she said. The new RFI creates considerable new uncertainty because of the potential for expansion of the Special Areas, making it more difficult for companies to make investment decisions. Alaska’s congressional delegation has also waded into this. In a joint letter to Alaska BLM Director Steve Cohn, also written in mid-September, Alaska senators Lisa Murkowski and Dan Sullivan and Rep. Mary Sattler Peltola said, “BLM’s actions are simply not a reasonable interpretation of federal law, let alone the best interpretation of federal law.” The agency has upended its management mission in the NPR-A from one led by responsible resource development to one defined by relentless conservation. BLM should have allowed the courts to review and decide on the multiple challenges to the final rule before issuing the RFI. The agency should instead use the next IAP process to decide the future of Special Areas. “The process by which BLM is undertaking the RFI is not transparent, will hide relevant information from policymakers and the public, and any decisions based on it will be unilaterally made behind closed doors without a true public process,” the delegation wrote. Throughout the development of the new NPR-A land management rule the BLM has failed to engage with North Slope communities and tribal groups, the delegation said. ALASKA RESOURCE REVIEW FALL 2024 34 CONTINUED FROM PAGE 32 Geologic Consulting Geologic Staffing Geologic Engineering Reporting (including 43-101) Logistics/ Operation Coordination Remote Sie Management GIS Services Permitting Assistance Community Engagement Claims Staking Claims Administration Equipment Rental Dedicated to responsible development of Alaska’s resources.
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