As you well know, Alaska is on the front lines of climate change that imminently threatens 87% of Alaska Native communities.

The Alaska Oil and Gas Conservation Commission​ has the the power to significantly slash the state's carbon emissions simply by enforcing existing statutes (outlined below) that require industry to minimize waste, i.e. largely methane, a powerful greenhouse gas.

The Alaska Department of Environmental Conservation 1990-2015 Greenhouse Gas Inventory Report concludes that more than half of Alaska’s GHG emissions comes from the oil and gas sector. Of that, fugitive methane from oil and gas production contributed over 19% of GHG emissions in 2015.

As Chair, we urge you to direct the Alaska Oil and Gas Conservation Commission to enforce existing statutes* requiring Alaska’s oil and gas industry to stop all non-emergency venting and flaring from Alaska oil and gas wells. This single, but powerful step would reduce our total greenhouse gas emissions significantly and send a clear message to Alaskans, the nation and world that your administration takes climate change seriously.

Methane (CH4) is a potent greenhouse gas (GHG) capable of trapping more than 25 times more solar radiation than CO2 over a 100-year period. According to Alaska Oil and Gas Conservation Commission (AOGCC) data, the oil and gas industry flared over 17 million cubic feet (McF) of GHG emissions between 2012 and 2017; an average of nearly 3 McF per year, roughly equivalent to 30% of the average annual demand of the Railbelt utility system.

Stopping flaring and venting of methane on the North Slope and Cook Inlet was unanimously supported by the oil and gas industry representatives on Governor Palin’s Mitigation Advisory Group in 2008 yet no Alaska official has ever acted on this recommendation. With climate change now front and center in all regions of Alaska, enforcing existing statutes is the low-hanging fruit for Alaska to take a giant step in reducing harmful greenhouse gas emissions.

*The following four Alaska State statutes and regulations provide clear jurisdiction for the AOGCC to compel Alaska’s oil and gas industry to minimize GHG emissions:

§AS 31.05.027 gives AOGCC authority over all land in the state of Alaska lawfully subject to its police powers, including Federal lands,

§AS 31.05.095 clearly states, “the waste of oil and gas in the state is prohibited”,

§AS 31.05.170(15) defines “waste” in addition to its ordinary meaning, “physical waste” and includes the inefficient, excessive, or improper use of, or unnecessary dissipation of, reservoir energy; and the locating, spacing, drilling, equipping, operating or producing of any oil or gas well in a manner which results or tends to result in reducing the quantity of oil or gas to be recovered from a pool in this state under operations conducted in accordance with good oil field engineering practices; the inefficient above-ground storage of oil; and the locating, spacing, drilling, equipping, operating or producing of an oil or gas well in a manner causing, or tending to cause, unnecessary or excessive surface loss or destruction of oil or gas; and other producing oil or gas in a manner causing unnecessary water channeling or coning; the operation of an oil well with an inefficient gas-oil ratio; the drowning with water of a pool or part of a pool capable of producing oil or gas; underground waste; the creation of unnecessary fire hazards; the release, burning, or escape into the open air of gas, from a well producing oil or gas; the use of gas for the manufacture of carbon black; and the drilling of wells unnecessary to carry out the purpose or intent of this chapter; and

20 ACC 25.235(d) further defines waste as “gas released, burned, or permitted to escape into the air” with the exclusion of necessary emergency and operations related emissions.

The latest International Panel on Climate Change (IPCC) report leaves no doubt; the window of opportunity for averting climate catastrophe is shrinking. At best, we have twelve years to substantially cut GHG emissions. As you have often stated, Alaska must do its part. Taking this definitive step will not only vastly improve air quality in impacted communities but it could reduce costs for industry and increase revenue for the state.

We implore you to use your authority as Chair of AOGCC to address the egregious violations of Alaska State statutes regarding emissions of methane waste.

Sincerely,