4 Reasons the Willow Oil Project Is Unfit for Approval

A new scientific study published in July found that the Arctic is warming four times faster than the rest of the world. In particular, climate change is having truly profound impacts in Alaska, which is saying something considering that roads are melting in Europe, U.S. national parks are closing from floods and fire, and the water supply in Western states is shrinking at a dramatic rate. At the same time, the Arctic is home to new drilling proposals in extreme and remote areas that have no business being turned into the next major oil hub. Scientists have made it clear that the United States must be looking to transition its economy to clean energy for the sake of our lives, livelihoods, and the planet; locking in decades of new drilling would be a massive step backward.

One such project is the ConocoPhillips Willow oil drilling project in the Western Arctic. After initially being approved by the Trump administration in 2020, then struck down by the courts in 2021, the Willow project is one of the most significant climate decisions in the hands of the Biden administration. The project is in direct conflict with the administration’s climate obligations and the subsistence and wildlife values of the Western Arctic.

On July 8, 2022, the Biden administration’s Bureau of Land Management (BLM) released a supplemental environmental impact statement for a “Willow Master Development Plan” proposed by ConocoPhillips. The document lays out potential avenues forward—including two options preferred by ConocoPhillips and one “no action alternative” that would reject the proposal outright—but does not signal which path the administration will take. Notably, since the environmental review for Willow began, a slow drip of new information has further highlighted the risks and incompatibility of the project with BLM’s legal mandates and the administration’s policies. The current supplemental review is unacceptably narrow should BLM move forward with anything other than a rejection of the plan.

This column lays out the top four reasons why the administration needs to reject the plan or go back to the drawing board:

1. The proposed project is a climate disaster in waiting.
2. The analysis for the project covers only a sliver of ConocoPhillips’ plans for the area.
3. New information on the risk of gas leaks has not been properly assessed.
4. ConocoPhillips has played an influential role in the environmental review.

Taken together, all evidence points to the need to reject the proposal outright, which is well within the legal authority of the Biden administration. Anything less would require the administration to complete a more comprehensive analysis that takes into account the full scale of the project, the risks of gas leaks, and the dire threat of climate change.

1. Willow is a climate disaster in waiting

Because the Trump-era climate analysis was thrown out by the courts for being insufficient, the newly released supplemental environmental impact statement (SEIS) updates the estimates of carbon that would be released if Willow were approved. And the new numbers are even more damning.

Developing and burning oil from the Willow project would produce up to 287 million metric tons of carbon dioxide over the next 30 years at a time when the United States urgently needs to move away from fossil fuels. That’s equal to the annual emissions of 76 coal power plants—a third of all coal plants in the United States. If approved, emissions from the Willow project would eclipse those avoided through achieving the Biden administration’s renewable energy goals on public lands and waters by 2030.

During his first months in office, President Joe Biden set the most ambitious climate goal of any U.S. president: to reduce carbon emissions by more than 50 percent by 2030. But the Willow project is a climate disaster in waiting. If any piece of the proposal is approved, a more thorough accounting of its climate risks will be necessary—including whether those risks fit under a scenario where the United States reduces carbon emissions by more than 50 percent by 2030.

2. The analysis fails to account for the full scale of ConocoPhillips’ development plans

Willow is just step one of ConocoPhillips’ plan to develop the Western Arctic and create a network of infrastructure that stretches far beyond the currently proposed project.

ConocoPhillips’ senior vice president for global operations told investors as much at a June 2021 meeting, calling Willow the “next great Alaska hub” and noting that the company had already “identified up to 3 billion BOEs [barrels of oil equivalent] of nearby prospects and leads with similar characteristics that could leverage the Willow infrastructure.” For context, 3 billion barrels of oil is equivalent to the annual carbon emissions of every car, truck, plane, and other form of transportation used in the United States combined. A slide deck accompanying the presentation highlighted that Willow’s “infrastructure hub unlocks the West” and that its design was intended for expansion. This is all at a time when scientists say that if the United States is to hit its climate goals, the country cannot afford to have any more fossil fuel development, never mind infrastructure buildout that extends far into the future. The International Energy Administration has said specifically that “there is no need for investment in new fossil fuel supply in our net zero pathway.”

BLM has, so far, failed to require ConocoPhillips to disclose the full extent of its plans and instead has approved each new development in isolation, failing to consider the overall picture and impact. Over the past decade, ConocoPhillips has developed a string of projects in Western Alaska, each dependent on the previous one, as the company progressively encroaches toward and into the Teshekpuk Lake Special Area, fragmenting the habitat and contributing to noise, disturbance, and air pollution for the mostly Indigenous community of Nuiqsut, turning their traditional land into an industrial zone. Public comments from the Kuukpik Village Corporation in Nuiqsut recognize this fact, noting: “Conoco has already indicated it intends to expand from Willow to access oil that won’t be reachable from the drill sites it’s currently proposing … So even Conoco acknowledges that they expect to be back in a few years asking BLM to approve more drill sites in this area.”

The project currently under review represents only a fraction of what ConocoPhillips has planned for the region, and the analysis does not consider the impacts from the full scale of the project that ConocoPhillips executives have sold to their shareholders. While an honest assessment may take more time to complete, the administration cannot approve what is known to be just a snippet of something bigger.

3. BLM must account for the risk of gas leaks

This March, a methane gas release occurred at ConocoPhillips’ Alpine Field drilling site, not far from the proposed Willow project, leading to the evacuation of personnel from the site as well as the departure of families from the nearby village of Nuiqsut who feared it was too dangerous to stay. ConocoPhillips’ incident report blamed the leak on a shallow gas zone that was previously undetected and indicated that thawing permafrost played a role in the severity of the leak. This finding is directly relevant to the Willow project given plans to use “chillers” to freeze the melting permafrost in order to build the infrastructure needed to drill for oil.

The initial Trump-era Willow project analysis contained only a passing reference to potential air quality impacts from a gas blowout of this kind and was generally dismissive of these types of leaks. Moreover, comments on that analysis relating to gas leaks were largely dismissed by BLM as “very unlikely” and “no cause for concern.” The most recent, 400-plus page draft review included just two paragraphs acknowledging the leak at Alpine but did not include new analysis or acknowledge the impacts that the event had on the surrounding community.

Furthermore, the Alaska Oil and Gas Conservation Commission is still undergoing a review of the accident and has not yet published its findings, which could be critical to preventing future gas leaks. Because the review is still pending, BLM’s supplemental analysis did not have all the information it needed to properly consider the risks of a similar accident at Willow. The threats posed by shallow well gas and melting permafrost are cause for a serious reassessment to protect public health.

If BLM does anything but reject the proposal, it must have all the information from the investigation to fully address the risk of a similar accident at Willow.

4. ConocoPhillips appears to have been influential in the review of the project

ConocoPhillips, which has already brought in nearly $10 billion in profit so far this year, obviously has an interest in the Willow project going through as quickly and as close to the company’s vision as possible. But because of this interest, there are, understandably, concerns about how closely the company has been involved in development of BLM’s environmental analyses.

From day one, ConocoPhillips played an active role in its own project approval and appears to be a fox guarding the henhouse. According to documents received under the Freedom of Information Act (FOIA), ConocoPhillips was directly involved in analyzing the court’s decision that overturned the initial environmental review of the project to determine next steps.* Along with the SEIS contractor, who ConocoPhillips also picked, the company participated in the development of a supplemental review seemingly intended to narrowly “fix” the issues found in the court ruling, rather than consider the full impact of the proposal.

A set of notes from a September 1, 2021, “post-judicial ruling” meeting between BLM, ConocoPhillips, and the contractor include clear timing preferences for project approval from ConocoPhillips, including that the company’s “goal is to have a Record of Decision (ROD) by mid-year 2022.” They also indicate that ConocoPhillips will be prepared to provide “support staff” to address the development of alternative project designs.

Environmental review of the project must be comprehensive and ensure that ConocoPhillips’ heavy hand does not unduly influence the analysis, the timeline, or BLM’s ultimate decision on the project

Conclusion

Rejecting the Willow project should be an easy choice. The world simply cannot take the carbon it has to offer, and the environmental review, as it stands, is inadequate. The Biden administration must not let ConocoPhillips’ steps toward quick and expansive development drive a decision that holds such fundamental importance to its climate legacy.

The window to act on climate is rapidly closing. Every new fossil fuel project makes it that much harder for humanity to do what is needed to avert truly catastrophic climate change. ConocoPhillips can afford to wait; President Biden cannot afford to get this decision wrong.

The author would like to thank Nicole Gentile, Sally Hardin, Steve Bonitatibus, Layla Hughes, Bridget Psarianos, and Brook Brisson for their contributions to this column.

*Author’s note: Citations for this section were received from a request under the FOIA. These documents, which include communications between ConocoPhillips and BLM concerning the Willow project, are on file with the author.