March 9, 2022

The Honorable Debra Haaland
Secretary of the Interior
U.S. Department of Interior
1849 C St., NW-6156
Washington, D.C. 20240

Dear Secretary Haaland,

The Honorable Debra Haaland Secretary of the Interior U.S. Department of Interior 1849 C St., NW-6156 Washington, D.C. 20240  1damaging proposal will be a significant test of this administration’s commitment to bringing the management of our nation’s public lands into line with the urgent need to combat the climate crisis and your goal to preserve 30 percent of our nation’s public lands by 2030. Careful analysis will confirm that declining to approve the Willow project is aligned with climate science and essential for the Biden administration to exercise global climate leadership.

Much more must be done to slash our nation’s greenhouse gas emissions to at least meet the Biden administration’s goal of 50 percent below 2005 levels by 2030. Pivoting from fossil fuel production on federal public lands—which accounts for 25 percent of U.S. greenhouse gas emissions—is a crucial part of achieving this goal and preventing climate disaster. Willow is the single largest oil extraction project currently proposed on U.S. federal lands, estimated to produce 590 million barrels of oil over thirty years, which is more potential carbon than 56 million cars would emit in a year. This project alone would offset a substantial portion of the carbon reductions achieved from the revised light-duty vehicle emissions standards announced in December 2021. Furthermore, the Willow project will enable even more industrial expansion into ecologically sensitive areas of the Western Arctic, producing billions more barrels of oil for decades to come. Numerous scientific studies have long concluded that expanded oil drilling activities in the Arctic is incompatible with meeting necessary climate targets.

The Willow project’s climate impact is heightened by its location in the Western Arctic, the cultural homeland and subsistence area for a number of Alaska Native communities. The Willow project would bring significant industrial impacts to this remote region, which is suffering severe stress as it warms three times faster than rest of the world. The project would include up to five drill pads with up to fifty wells on each pad, an extensive road system that includes hundreds of miles of water-intensive ice roads, hundreds of miles of pipelines, a gravel mine, and a new processing facility. What’s more, because the permafrost is rapidly thawing due to the accelerating impact of climate change, ConocoPhillips’ has admitted that it plans to artificially chill the melting tundra to even sustain this expansive oil and gas infrastructure. This high level of development investment would cause direct damage on the ground as it threatens to lock in oil production for decades.

The Willow project would also irreparably damage a sensitive and globally significant ecosystem around Teshekpuk Lake. The world has lost two-thirds of its wildlife in the last 50 years and the Teshekpuk Lake area provides vital nesting habitat for hundreds of thousands of migratory birds from around the globe, supporting the highest density of shorebirds in the circumpolar Arctic. It is also the primary calving ground and a key foraging and insect-relief area for the Teshekpuk Lake Caribou Herd, a vital subsistence resource for communities in Arctic Alaska. This is the only herd that stays in the Arctic all year and this project would expose the herd to year-round industrial activity, while also threatening to cut off the animals’ migration route, exacerbating the stress this herd is already suffering from climate change. The Western Arctic and the Willow project area also provide critical denning habitat for threatened polar bears. Impacts from Willow’s industrial sprawl would further exacerbate the stress these irreplaceable species are already suffering from climate change.

In responding to the court decision vacating the Gulf of Mexico lease sale, the Department reiterated its commitment to follow “the law, science and sound policy,” and “make significant and long overdue programmatic reforms” in its federal oil and gas program “in the face of the climate crisis.” Recent court decisions from across the country, including the Alaska District Court decision that invalidated the Willow project’s approval, and the D.C. District Court’s decision invalidating an 80-million-acre lease sale in the Gulf of Mexico, underscore the government’s legal obligation to accurately consider the long-term climate impacts of oil and gas development.

The decision your administration will make on the Willow Project is a legacy-defining decision that could commit us to at least another 30 years of fossil fuel extraction. It will also begin the aggressive development of a region that houses enough fossil fuels that, if burned, would equal more than double the carbon emissions of burning all the oil that the Keystone XL pipeline would have carried over its 50-year lifespan, had it been approved.

Declining to approve the proposed Willow project and its highly problematic carbon
implications would be an important step in the fulfillment of the Biden administration’s commitments to sound policy and science, as well as in the work to fully deliver on your long-term climate and environmental justice promises.

Sincerely,