2023 Willow MDP Record of Decision

U.S.
Department of the Interior

Bureau of Land Management
Willow Master Development Plan

Supplemental Environmental Impact Statement
Record of Decision
March 2023
Prepared by:
U.S. Department of the Interior
Anchorage, Alaska
In Cooperation with:
U.S. Army Corps of Engineers
U.S. Environmental Protection Agency
U.S. Fish and Wildlife Service
Native Village of Nuiqsut
Iñupiat Community of the Arctic Slope
City of Nuiqsut
North Slope Borough
State of Alaska
Estimated Costs
Developing and Producing the Initial EIS: $6,971,120
Developing and Producing the Supplemental EIS: $3,685,000
Total: $10,656,120
Mission
To sustain the health, diversity, and productivity of the
public lands for the future use and enjoyment of present and
future generations.
Cover Photo Illustration: North Slope Alaska oil rig during winter drilling.
Photo by: Judy Patrick, courtesy of ConocoPhillips.
Photo copyright 2019 ConocoPhillips Alaska, Inc. The BLM is permitted to use this photo and copy for its own use;
any other use or copying by any other party is prohibited without the written consent of ConocoPhillips Alaska, Inc.
DOI-BLM-AK-0000-2018-0004-EIS
BLM/AK/PL-22/032+1610+F010
Record of Decision
March 2023
This page intentionally left blank.
Record of Decision for the Willow Master Development Plan
LEAD FEDERAL AGENCY Bureau of Land Management (BLM)
PROPONENT ConocoPhillips Alaska, Inc.
APPLICATION REFERENCE NUMBER BLM Case File FF097428
RESPONSIBLE OFFICIAL Tommy P. Beaudreau

Deputy Secretary of the Interior
FOR INFORMATION CONTACT Steven M. Cohn

State Director
BLM Alaska
(907) 271-5080
Willow Master Development Project Record of Decision
Supplemental Environmental Impact Statement March 2023
TABLE OF CONTENTS
1.0 INTRODUCTION ........................................................................................................................... 1
1.1 Background ................................................................................................................................... 1
1.2 Authorities..................................................................................................................................... 2
2.0 DECISION ....................................................................................................................................... 2
3.0 PROJECT DESCRIPTION .............................................................................................................. 3
3.1 Selected Alternative Description .................................................................................................. 3
3.2 Project Location ............................................................................................................................ 4
4.0 ALTERNATIVES............................................................................................................................ 7
4.1 Alternatives Considered and Carried Forward for Detailed Analysis in the Supplemental EIS ... 7
4.2 Rationale for Decision Adopting Alternative E as modified [BT1, BT2 and BT3 approved; BT5
disapproved] and Module Delivery Option 3 ............................................................................... 8
5.0 PUBLIC INVOLVEMENT ........................................................................................................... 13
5.1 Public Notices ............................................................................................................................. 13
5.2 Previous Public Involvement ...................................................................................................... 13
5.3 Public Involvement for the Supplemental EIS ............................................................................ 13
5.4 Evaluation and Consideration of Comments Received ............................................................... 14
5.4.1 Comments Received Prior to the Final Supplemental EIS ................................................. 14
5.4.2 Comments Received After the Final Supplemental EIS ..................................................... 15
5.5 Engagement with Environmental Justice Communities.............................................................. 15
6.0 RELATED LAWS AND POLICIES ............................................................................................. 16
6.1 Alaska National Interest Lands Conservation Act ...................................................................... 16
6.2 Endangered Species Act .............................................................................................................. 17
6.3 Clean Air Act .............................................................................................................................. 17
6.4 Clean Water Act .......................................................................................................................... 17
6.5 Coastal Zone Management Act ................................................................................................... 17
6.6 Fish and Wildlife Coordination Act ............................................................................................ 18
6.7 Materials Act ............................................................................................................................... 18
6.8 Magnuson-Stevens Fishery Conservation and Management Act ................................................ 18
6.9 Mineral Leasing Act.................................................................................................................... 18
6.10 National Historic Preservation Act ............................................................................................. 18
6.11 Executive Order 11988 (Floodplain Management) ..................................................................... 19
6.12 Executive Order 11990 (Wetlands) ............................................................................................. 20
6.13 Executive Order 13112 (Invasive Species) ................................................................................. 21
6.14 Executive Order 12898 (Environmental Justice) ........................................................................ 21
6.15 Executive Order 13175 (Consultation and Coordination with Indian Tribal Governments) ...... 23
7.0 OTHER AUTHORIZATIONS ...................................................................................................... 23
8.0 FINAL AGENCY ACTION .......................................................................................................... 25
8.1 Bureau of Land Management Recommendation ......................................................................... 25
8.2 Departmental Approval ............................................................................................................... 27
9.0 REFERENCES .............................................................................................................................. 29
i
LIST OF TABLES
Table 1. Summary of Rationale for Selected Alternative and Option ........................................................ 10
LIST OF FIGURES
Figure 1. Willow Master Development Plan Selected Project ...................................................................... 5
LIST OF APPENDICES
Appendix A Mitigation Measures
Appendix B Alaska National Interest Lands Conservation Act Section 810 Compliance
ii
ACRONYMS AND ABBREVIATIONS
ANILCA Alaska National Interest Lands Conservation Act
APE area of potential effects
BLM Bureau of Land Management
BT1 Bear Tooth drill site 1
CAA Clean Air Act
CPAI ConocoPhillips Alaska
CRSA Colville River Special Area
CWA Clean Water Act
Decision Record of Decision
District Court U.S. District Court for Alaska’s
DOI U.S. Department of the Interior
DS2P Kuparuk drill site 2P
EFH Essential Fish Habitat
EIS Environmental Impact Statement
EO Executive Order
ESA Endangered Species Act
FLPMA Federal Land Policy and Management Act
GMT Greater Mooses Tooth
GMT-2 Greater Mooses Tooth 2
LS lease stipulation
MDP Master Development Plan
MLA Minerals Leasing Act
NEPA National Environmental Policy Act
NHPA National Historic Preservation Act
NMFS National Marine Fisheries Service
NPR-A National Petroleum Reserve in Alaska
NPRPA Naval Petroleum Reserves Production Act
NRHP National Register of Historic Places
NSB North Slope Borough
Project Willow Master Development Plan Project
Proponent ConocoPhillips Alaska, Inc.
ROD Record of Decision
ROP Required Operating Procedure
ROW right-of-way
SHPO State Historic Preservation Officer
SDEIS Supplemental Draft Environmental Impact Statement
TLSA Teshekpuk Lake Special Area
USACE U.S. Army Corps of Engineers
USFWS U. S. Fish and Wildlife Service
WOC Willow Operations Center
WPF Willow Processing Facility
WQC Water Quality Certification
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Page iv
1.0 INTRODUCTION
This document constitutes the U.S. Department of the Interior’s (DOI) Record of Decision (ROD or
Decision) under the National Environmental Policy Act (NEPA) for approval of the Willow Master
Development Plan (MDP) Project (Project), allowing for construction and operation of infrastructure
proposed by ConocoPhillips Alaska, Inc. (the Proponent or CPAI), necessary to allow the production and
transportation to market of federal oil and gas resources in the Willow reservoir located in the Bear Tooth
Unit, while providing maximum protection to significant surface resources within the National Petroleum
Reserve in Alaska (NPR-A or Reserve), consistent with the Bureau of Land Management’s (BLM)
statutory directives.
This Decision is prepared in accordance with the Naval Petroleum Reserves Production Act (NPRPA), as
amended (42 USC 6501-08), Section 302 of the Federal Land Policy and Management Act (FLPMA) (43
USC 1732), Section 28 of the Mineral Leasing Act (MLA) (30 USC 185), and Section 810 of the Alaska
National Interest Lands Conservation Act (ANILCA) (16 USC 3120).
This ROD memorializes DOI’s decision to select Alternative E from the Final Supplemental EIS as
modified herein. Among other things, Alternative E eliminates drill site BT4. This Decision approves drill
sites BT1, BT2 and BT3 as analyzed under Alternative E and disapproves, rather than defers, drill site
BT5 and associated infrastructure. This Decision also approves Module Delivery Option 3 (Colville River
Crossing), with special conditions, for the Project, as detailed in the January 2023 Willow MDP Final
Supplemental Environmental Impact Statement (EIS) and as discussed below. The scope of this Decision
is limited to the components of the Project that occur on BLM-managed public lands in the NPR-A.
Access to other lands is subject to landowner approval, and other federal, state, and local agencies will
process applications for authorizations under their respective jurisdictions and authorities. Subsequent to
this Decision approving the Willow MDP, the Proponent may receive approval of applications for BLM
authorizations, including permits and rights-of-way (ROW), for the facilities and activities described in
Section 3.0 (Project Description) below.
1.1 Background
The Willow MDP Final Environmental Impact Statement was published in August 2020, followed by the
BLM and then–Secretary of the Interior signing a ROD in October 2020 (the 2020 ROD). The 2020 ROD
approved the development of Alternative B, the Proponent’s proposed five drill site project. At the
Proponent’s request, the ROD included authorization for only part of the Willow MDP under Alternative
B, approving three drill sites (BT1, BT2 and BT3) and deferring decisions on two drill sites (BT4 and
BT5).
In August 2021, the U.S. District Court for Alaska (District Court) vacated the ROD and remanded the
matter to the BLM, finding that the BLM: 1) improperly excluded analysis of foreign greenhouse gas
emissions, 2) improperly screened out alternatives from detailed analysis based on BLM’s
misunderstanding of leaseholders rights (i.e., that leases purportedly afforded the right to extract “all
possible” oil and gas from each lease tract), and 3) failed to give due consideration to the requirement in
the NPRPA to afford “maximum protection” to significant surface values in the Teshekpuk Lake Special
Area (TLSA).
BLM prepared a Draft Supplemental EIS to address the District Court’s decision and issued it on July 11,
2022. The Notice of Availability for the Final Supplemental EIS was published in the Federal Register on
February 3, 2023.
The Supplemental EIS was prepared by BLM as the lead agency, with the assistance of the following
cooperating agencies: U.S. Army Corps of Engineers (USACE), U.S. Fish and Wildlife Service
(USFWS), U.S. Environmental Protection Agency, State of Alaska, North Slope Borough (NSB), Native
Village of Nuiqsut, City of Nuiqsut, and the Iñupiat Community of the Arctic Slope. This process resulted
in a Final Supplemental EIS, consistent with NEPA, that provided a detailed analysis of the
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environmental impacts of the Proponent’s proposal and an expanded range of alternatives, including the
No Action Alternative, to inform and support the reviews and decisions of BLM and cooperating agencies
for the Project.
1.2 Authorities
As the federal manager of the NPR-A, BLM is responsible for land-use authorizations and associated
compliance with the requirements of NEPA (42 USC 4321 et seq.). The authority for management of the
land and resource development options presented in the Final Supplemental EIS is pursuant to the
NPRPA, FLPMA, MLA, ANILCA, and the Materials Act of 1947. Additionally, USACE, a cooperating
agency, also has authority over the Project through its authority to issue or deny permits for the placement
of dredge or fill material in Waters of the United States, including wetlands. Final Supplemental EIS,
Appendix C, Regulatory Authorities and Framework, includes additional BLM authorities, policies,
regulations, and guidance discussion.
2.0 DECISION
This ROD approves the development of project Alternative E as described in the Final Supplemental EIS,
as modified to include only drill sites BT1, BT2 and BT3 and associated infrastructure, and the
development and use of Module Delivery Option 3 (Colville River Crossing), subject to the terms and
conditions described in Appendix A, Mitigation Measures, of this ROD. Additional project details are
described below in Section 3.0 Project Description. In doing so, this Decision adopts a minor variation of
Alternative E as analyzed in the Final Supplemental EIS. This Decision disapproves BT5 and its
associated infrastructure, rather than deferring a decision on BT5, while maintaining the same drill site
locations for the three approved drill sites analyzed in Alternative E.
Actions covered by this Decision are the approval of the Willow MDP and the associated issuance of
subsequent authorizations, including permits and ROWs, for the construction and operation of the Project,
based on the analysis contained in the Supplemental EIS. This ROD does not constitute the final approval
for all actions, such as approval for related individual applications for authorizations, including (but not
limited to) permits to drill and ROWs associated with the Project. See Appendix C of the Final
Supplemental EIS for additional information regarding applicable BLM authorizations and requirements.
The Proponent is hereby required to comply with all terms and conditions described or listed in Appendix
A of this ROD, including: applicable lease stipulations (LSs) for those oil and gas leases comprising the
Project area; required operating procedures (ROPs) required by the NPR-A Integrated Activity Plan in
effect at the time of subsequent permit issuance; design features incorporated by the Proponent; new
mitigation measures selected from the Final Supplemental EIS Appendix I (Avoidance, Minimization, and
Mitigation) (see Appendix A of this ROD, Section 3.0, Additional Mitigation Measures Adopted); and
other required measures as described in Appendix A of this ROD Section 5.0, Other Required Mitigation
Measures. In requiring compliance with these measures, the BLM has adopted all practicable means to
avoid or minimize environmental harm from the alternative selected and will implement a monitoring and
enforcement program for these requirements. Additional mitigation measures analyzed in the Final
Supplemental EIS but not adopted by this Decision are described in Section 4.0, Additional Mitigation
Measures Considered but Not Adopted, of Appendix A of this ROD, which includes BLM’s rationale for
not adopting the measures.
This ROD completes the required Supplemental EIS process and NEPA requirements for the subsequent
issuance of BLM approvals, grants, and other authorizations necessary for development of all aspects of
the Willow MDP on federal lands managed by BLM under Alternative E of the Final Supplemental EIS.
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3.0 PROJECT DESCRIPTION

3.1 Selected Alternative Description
The Project as approved in this Decision -- Alternative E as described in the Final Supplemental EIS, as
modified to include only drill sites BT1, BT2 and BT3 and associated infrastructure -- will include the
Willow Processing Facility (WPF), Willow Operations Center (WOC), airstrip, and three drill sites (BT1,
BT2 and BT3). Gravel roads will connect to all Project infrastructure and will extend from the Greater
Mooses Tooth 2 (GMT-2) development southwest toward the Project area (Figure 1, Willow Master
Development Plan Selected Project). As approved in this Decision, the Project will include up to 199 total
wells, four valve pads, three pipeline pads, five water source access pads, pipelines to support Project
infrastructure, and up to three subsistence-use boat ramps. BT2 will be located north of Fish Creek to gain
access to a portion of the target reservoir. See the Final Supplemental EIS, Chapter 2, Section 2.5.1
Project Facilities and Gravel Pads, for descriptions of these components. The subsistence-use boat ramps
were added to the Project by CPAI as mitigation to help offset Project effects on the community of
Nuiqsut – see Final Supplemental EIS Section 2.5.13, Boat Ramps for Subsistence Users.
The access road alignment will provide direct gravel-road access from the existing gravel road network in
the Greater Mooses Tooth (GMT) Unit and Alpine developments to the Project facilities. The full, all-
season gravel road connection to Alpine will allow for additional operational safety and risk reduction by
providing redundancies and additional contingencies for each development.
Ice roads will be used during Project construction to support gravel placement and pipeline construction,
to access the gravel mine site, and to transport sealift modules from Oliktok Dock to the Project area.
Separate ice roads will be used for pipeline construction, gravel placement, and general traffic to address
safety considerations. A partially grounded ice bridge across the Colville River near Ocean Point will be
used to transport sealift modules to the Willow area. The ice road will originate at the end of the existing
Kuparuk road system at Kuparuk drill site 2P (DS2P).
Infield (multiphase) pipelines will connect individual drill sites to the WPF, and export/import pipelines
will connect the WPF eastward to existing infrastructure on the North Slope. Diesel fuel will be piped
from Kuparuk CPF2 to the Alpine Central Processing Facility and then trucked to the Project area.
The Project will include at least two Class I underground injection control disposal wells, both located at
the WOC. The Project will use an existing mud plant located on the K-Pad, near Alpine CD5, to produce
drilling mud, which eliminates the need to construct a new mud plant at the WOC. The existing K-Pad
mud plant will be expanded on the existing gravel pad to support this use. The Project will also include
installation of two additional modules on the existing GMT-2 drill site pad to allow for the possibility of
transporting GMT-2 produced fluids westward to the WPF in case of future need.
Electrical power for the Project will be generated by a 98-megawatt power plant at the WPF, equipped
with natural gas–fired turbines. Power will be delivered to each drill site and the WOC via power cables
suspended from pipeline horizontal support members.
Gravel will be primarily obtained from a new gravel mine site in the Tiŋmiaqsiuġvik area, approximately
4 to 5 miles southeast of Greater Mooses Tooth 1. The gravel mine site will be accessed seasonally via ice
road; no permanent gravel road to the mine site will be constructed. There will be no activity at the mine
site outside of the winter construction season. Small amounts of gravel will also be obtained from existing
mine sites C and E in Kuparuk, to widen sections of existing Kuparuk roads that will be used for module
transport.
Sealift module delivery will use the existing Oliktok Dock to receive the sealift barges. The modules will
be transported over existing Kuparuk gravel roads using self-propelled module transporters from Oliktok
Dock to Kuparuk DS2P. From Kuparuk DS2P, the modules will then be moved by heavy-haul ice roads
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to GMT-2, crossing the Colville River on a partially grounded ice bridge near Ocean Point. From GMT-2,
the modules will be transported to the Project area over Project gravel roads to reach the WPF and drill
site gravel pads. See Final Supplemental EIS Sections 2.5.3.4 Sealift Barge Deliver to Oliktok Dock, and
2.6.3, Option 3: Colville River Crossing, for additional details.
3.2 Project Location

The Project is located on the North Slope of Alaska, with the majority of the proposed facilities on leased
federal lands within the Bear Tooth Unit in the northeastern portion of the NPR-A. Supporting
infrastructure, including road connections, pipeline tie-ins, and the gravel mine site, would be located on
federal and Native Corporation–owned lands in the GMT Unit, on non-unitized lands within the NPR-A,
and on lands or waters owned and managed by the State of Alaska. As approved in this Decision, none of
the facilities would be constructed on Native allotments.
Elements of the Project would occur within the TLSA of the NPR-A (as defined in the 2022 NPR-A
IAP/EIS ROD [BLM 2022]), which was identified as a special area in the NPRPA and designated by the
Secretary of the Interior in 1977 for its significant value to waterfowl and shorebirds. The designation has
since been expanded to protect caribou and waterbirds, and their habitats.
Page 4
Record of Decision Willow Master Development Plan Selected Project
U.S. DEPARTMENT OF THE INTERIOR | BUREAU OF LAND MANAGEMENT | ALASKA | WILLOW MASTER DEVELOPMENT PLAN
INSET B Willow Proposed Development Features

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Dock
Existing Road
Oliktok Existing Pipeline
Dock Existing Infrastructure
Oil and Gas Unit
INSET B Bear Tooth Unit
NPR-A Special Areas
Colville River Special Area
Teshekpuk Lake Special Area
Required Operating Procedure
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4.0 ALTERNATIVES
Considering alternatives helps to ensure that ultimate decisions concerning projects are well founded and
consistent with national policy goals and objectives (33 CFR 325 Appendix B (7), 40 CFR 230.5(C), and
40 CFR 1502.14). NEPA requires that an EIS include a discussion of a range of reasonable alternatives,
including the No Action Alternative, and the effects of those alternatives. The term reasonable as defined
in NEPA regulations is based on consideration of a project’s purpose as well as technology, economics,
and common sense.
Under Clean Water Act (CWA) Section 404(b)(1) Guidelines, practicability of alternatives is taken into
consideration and no alternative may be permitted if there is a less environmentally damaging practicable
alternative. Practicable is defined in the CWA regulations as meaning the alternative is available and
capable of being done after taking into consideration cost, existing technology, and/or logistics in light of
the overall project purpose (40 CFR 230.3(q)).
4.1 Alternatives Considered and Carried Forward for Detailed Analysis in

the Supplemental EIS
In preparing the Supplemental EIS, the BLM and cooperating agencies developed an expanded range of
alternatives (four action alternatives, including the Proponent’s proposal, and the No Action Alternative)
to address the District Court’s decision. This range of alternatives was developed through an iterative
process that built upon the extensive coordination that occurred between BLM, CPAI, cooperating
agencies, Tribes and Alaska Native Corporations, and other stakeholders in formulating the alternatives
analyzed in the initial 2020 EIS. See Final Supplemental EIS, Appendix D.1, Section 3.2 (Alternatives
Development for the 2020 Environmental Impact Statement) for a complete summary of the alternatives
development process for the 2020 EIS including early coordination between the Proponent and BLM
focused on compliance with LSs and ROPs and how to best protect important resources within the TLSA
and Colville River Special Area (CRSA).
As presented in the Final Supplemental EIS, Chapter 2, and Appendix D.1, Section 3.5 (Alternatives
Development for the 2022 Supplemental Environmental Impact Statement), in developing new
alternatives concepts for the Supplemental EIS, BLM first reviewed public comments that were submitted
on the 2019 Draft EIS and 2019 Draft Supplemental EIS for any alternatives concepts that were
previously excluded from consideration but might now be relevant following the District Court’s
decision. BLM also consulted with key Alaska stakeholders to solicit input on potential alternative
concepts that would address the District Court’s decision. BLM then met with cooperating agencies to
develop an expanded range of alternatives for the Supplemental EIS based on the District Court’s
decision. BLM and cooperating agencies reexamined alternative concepts that were proposed during the
previous EIS process and worked to develop new alternative concepts that would reduce overall Project
infrastructure and impacts. New alternative concepts were developed with a focus on reducing
infrastructure within the TLSA and CRSA to provide for the “maximum protection” of surface values.
Options identified during the cooperating agencies’ alternatives development meetings included
elimination of proposed drill sites, relocation of proposed drill sites, revised access road alignment, and a
new disconnected (i.e., ice road access only) drill site option.
BLM also held a 30-day informal public scoping comment period to solicit public input on the
Supplemental EIS. Commenters suggested alternatives concepts such as variations on disconnected (i.e.,
no gravel road connection) three, four-, and five-drill site alternatives, a concept with seasonal drilling at
some or all of the satellite pads, alternative modes of transportation for module transport, use of the
Alpine Central Processing Facility to process fluids (e.g., water, oil, gas) produced by the Project, a three-
drill site alternative concept, and phased development of the Project.
Page 7
Potential new alternative concepts were evaluated against revised Project screening criteria (Final
Supplemental EIS, Appendix D.1, Section 3.5.1, Revised Screening Criteria for the Supplemental
Environmental Impact Statement). Alternatives or alternative components that met the screening criteria
were advanced as a new alternative and those that did not meet the screening criteria were dismissed from
further evaluation.
Project screening criteria were reevaluated and augmented while developing the Supplemental EIS to
ensure any new alternatives adequately addressed the District Court’s decision and were compliant with
applicable law. In its decision, the District Court remanded the Willow MDP EIS to BLM for the
following reasons:
• BLM acted contrary to law insofar as it developed its alternatives analysis based on the view that
CPAI had the right to extract all possible oil and gas from its leases.
• BLM acted contrary to law in its alternatives analysis for the TLSA insofar as it failed to consider
the statutory directive that BLM give “maximum protection” to surface values in that area.
All screening criteria from the previous Willow MDP EIS were retained (Final Supplemental EIS,
Appendix D.1, Section 3.1.1, Alternatives Screening Criteria) and a new screening criteria was adopted to
directly address the District Court’s reasons for remanding the Willow MDP EIS to BLM. The new
screening criteria is:
• Addresses the District Court’s decision: This screening criteria was developed in recognition of
the District Court’s finding that CPAI did not have unfettered right to extract “all possible” oil
and gas from its leases and to evaluate whether an alternative concept directly addresses the
District Court’s directive to BLM to consider alternatives that would reduce infrastructure and
environmental impacts relative to CPAI’s proposal (i.e., Alternative B), and specifically that
would reduce infrastructure and impacts within the TLSA.
See Chapter 2.0 and Appendix D.1 of the Final Supplemental EIS for a detailed description and
comparison of the alternatives considered and carried forward for detailed analysis in the Final
Supplemental EIS.
BLM and the cooperating agencies developed four action alternatives (Alternatives B, C, D, and E) and
the No Action Alternative (Alternative A) and three sealift module delivery options (Options 1, 2, and 3)
as the reasonable range of alternatives analyzed in detail in the Supplemental EIS.
The four action alternatives and no action alternative are as follows:
• Alternative A: No Action
• Alternative B: Proponent’s Project
• Alternative C: Disconnected Infield Roads
• Alternative D: Disconnected Access
• Alternative E: Three-Pad Alternative (Fourth Pad Deferred)
The three module delivery options are as follows:
• Option 1: Atigaru Point Module Transfer Island
• Option 2: Point Lonely Module Transfer Island
• Option 3: Colville River Crossing
4.2 Rationale for Decision Adopting Alternative E as modified [BT1, BT2

and BT3 approved; BT5 disapproved] and Module Delivery Option 3
Among the alternatives evaluated in the Supplemental EIS, Alternative E with Module Delivery Option 3
would result in fewer overall environmental impacts—including impacts to important surface resources,
subsistence uses and resources, and the climate—than the other action alternatives and module delivery
Page 8
options and therefore is considered by BLM to be the environmentally preferred alternative. This
alternative was developed by BLM and cooperating agencies to reduce impacts to surface resources,
particularly in the TLSA, in response to the Alaska District Court’s remand decision. Alternative E as
analyzed in the Final Supplemental EIS serves as the basis for the Decision, which adopts a minor
variation of Alternative E that is qualitatively within the spectrum of alternatives that were discussed and
analyzed in the Supplemental EIS. The discussion that follows generally first explains the reasons for
identifying Alternative E and Module Delivery Option 3 as the preferred alternative in the Final
Supplemental EIS followed by the rationale for selecting a variation of Alternative E involving the
disapproval of drill site BT5 (instead of its deferral) in this Record of Decision.
Of all the action alternatives and options analyzed in the Final Supplemental EIS, the combination of
Alternative E and Module Delivery Option 3, even with drill site BT5, requires the fewest ice roads,
fewest total miles of infield pipelines, least water use, fewest vehicle trips, fewest fixed-wing aircraft
trips, fewest helicopter trips, and fewest acres of screeding. Unlike Module Delivery Options 1 and 2,
Option 3 also requires no gravel fill in the marine area. These reductions in the amounts of facilities, use
of water and gravel, and operational activities substantially reduce impacts to important surface resources
and subsistence uses as compared to the other action alternatives. Additionally, Alternative E and Module
Delivery Option 3, even with drill site BT5, have the fewest total greenhouse gas emissions of all the
action alternatives, making their selection consistent with the principles and objectives outlined in
President Biden’s Executive Order 13990, entitled “Protecting Public Health and the Environment and
Restoring Science to Tackle the Climate Crisis” (Jan. 20, 2021) and Executive Order 14008, entitled
“Tackling the Climate Crisis at Home and Abroad” (Jan. 27, 2021), and Secretary Haaland’s Order No.
3399, entitled “Department-Wide Approach to the Climate Crises and Restoring Transparency and
Integrity to the Decision-Making Process” (April 16, 2021).
The Proponent’s proposed development plan is based on its oil and gas leases in the NPR-A. Those leases
provide that the authorization to drill for and extract oil and gas resources is subject to the terms and
stipulations of the lease, as well as applicable laws and regulations in effect at the time of lease issuance
and subsequently promulgated regulations and orders to the extent not inconsistent with the provisions of
the lease. Appendix A of this ROD contains the terms and conditions of approval, which are designed to
implement the terms and stipulations of the Proponent's leases. Moreover, the selected alternative is
specifically designed to comply with two sections of the NPRPA, both of which were in effect at the time
of lease issuance. First, 42 USC 6506a(b) provides that activities in the NPR-A “shall include or provide
for such conditions, restrictions, and prohibitions as the Secretary deems necessary or appropriate to
mitigate reasonably foreseeable and significantly adverse effects on the surface resources of” NPR-A.
Second, 42 USC 6504(a) requires the BLM to ensure that any exploration in the NPR-A in special areas
“shall be conducted in a manner which will assure the maximum protection of such surface values to the
extent consistent with the requirements of this Act for the exploration of the reserve.” (emphasis added.)
The adoption of Alternative E and Module Delivery Option 3 in this Decision, as modified to include
disapproval of drill site BT5, is intended to fulfill both of these statutory directives consistent with the
Proponent’s leases.
Specifically, this Decision reflects careful consideration of the Secretary’s statutory directive to provide
maximum protection to significant surface values within the NPR-A (i.e., Special Areas). As presented in
the Final Supplemental EIS, Alternative E requires less surface infrastructure, primarily within the TLSA,
than would be required under Alternatives B, C, or D due to the elimination of BT4 and its associated
infrastructure. Reducing the gravel infrastructure (e.g., gravel footprint, miles of gravel road, miles of
pipeline) will lessen impacts to wetlands and vegetation, hydrology, gravel resources, and wildlife.
Reducing the amount of overall infrastructure will also diminish potential impediments to the movement
of caribou and subsistence users. As compared to other action Alternatives, Alternative E, as described in
the Final Supplemental EIS, also requires the least length of pipelines and roads with less than 500 feet of
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separation, thereby reducing the occurrence of “pinch points” that may restrict caribou and subsistence
user movement. Additionally, disapproval of BT5 and its associated infrastructure further reduces the
total length of pipelines and roads and impacts associated with that infrastructure.
Table 1 summarizes approved Project components, how they minimize effects, and how they contribute to
the rationale for selection of Alternative E [BT1, BT2 and BT3 approved; BT5 disapproved] and Module
Delivery Option 3.
Table 1. Summary of Rationale for Selected Alternative and Option

Project Component Rationale for Selection
Infrastructure within • Substantially reduces the amount of surface infrastructure (e.g., gravel footprint,
TLSA and sensitive pipelines, ice roads) within the TLSA through the elimination of BT4.
areas • Reduces the impacts to identified yellow-billed loon nests located near the previously
proposed BT5 location through the elimination of BT5 and associated infrastructure (e.g.,
gravel footprint, pipelines, ice roads).
• Substantially reduces the amount of overall Project infrastructure (e.g., gravel footprint,
miles of gravel road, miles of pipeline) that may impede caribou movement and impact
wetlands, hydrology, birds, and subsistence users.
Number of wells • Has the least amount of production and injection wells (199 as approved versus 251 in
Alt. B).
• Has the least amount of projected oil production and associated greenhouse gas
emissions.
Mud plant • Uses an existing mud plant located on the K-Pad, near Alpine CD5, and eliminates the
need to construct a new mud plant at the Willow operations center.
Acres of freshwater • Has the smallest ice road and ice pad footprint.
ice infrastructure • Has the least impacts to vegetation and wildlife.
Water use • Has the least amount of freshwater requirements.
• Will not require a constructed freshwater reservoir.
Vehicle trips • Least potential for vehicle strikes of wildlife.
• Fewest number of vehicles causing dust from gravel infrastructure (and associated dust-
related effects to soils, permafrost, water resources, wetlands and vegetation, wildlife
forage resources, visual resources, etc.).
• Fewest emissions from vehicles.
• Least disturbance of wildlife and birds.
• Least amount of vehicle noise and visual contrast from vehicles and associated dust.
• Least impact to subsistence resources and access.
Fixed-wing aircraft • Least potential for bird strikes.
trips • Fewest aircraft emissions.
• Least amount of noise and visual contrast from aircraft.
• Least impactful to subsistence resources.
Helicopter trips • Least potential for bird strikes.
• Fewest helicopter emissions.
• Least amount of noise and visual contrast from helicopters.
• Least impactful to subsistence resources.
Acres of screeding • Least amount of suspended sediment and turbidity, which could affect water resources,
fish, birds, marine mammals, and subsistence users.
• Least amount of habitat alteration for fish, birds, and marine mammals.
• Least in-water and airborne noise and thus least disturbance and displacement of fish,
birds, and marine mammals.
• Least injury and mortality of fish in the screeding footprint.
• Fewest emissions from screeding.
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Project Component Rationale for Selection

Gravel fill in the • No permanent marine habitat loss or alteration for fish, birds, and marine mammals.
marine environment • Least in-water and airborne noise and thus least disturbance and displacement of fish,
birds, terrestrial mammals, and marine mammals.
• Least injury to and mortality of fish.
• Fewest emissions associated with sealift module and material delivery.
Notes: BT4 (drill site BT4); BT5 (drill site BT5); TLSA (Teshekpuk Lake Special Area).
Although Alternative E in the Supplemental EIS evaluates the full development of the Willow reservoir
with four satellite drill pads (BT1, BT2, BT3 and BT5), BT5 is disapproved in this ROD, as is BT4
(analyzed under Alternatives B, C and D).
As compared to the Proponent’s proposed project (Alternative B in the Final Supplemental EIS –
proposing five drill sites: BT1, BT2, BT3, BT4 and BT5), the project approved in this Decision (BT1,
BT2 and BT3 approved; BT4 and BT5 disapproved) significantly reduces the footprint of project
infrastructure and the level of construction and operational activities, both within and outside of the
sensitive TLSA, and thereby substantially reduces impacts to a broad range of surface resources. In
addition to lessening impacts to important surface resources such as wetlands and vegetation, hydrology,
gravel resources, and wildlife generally, of particular note is the reduction of adverse impacts to caribou
and their movement, and resulting adverse impacts to subsistence harvesting of caribou, from the
substantially reduced length of roads and pipelines associated with the elimination of BT4 and BT5 and
the elimination of year-round operations associated with those two drill sites. The Project’s impacts to
caribou and subsistence harvesting of caribou, particularly associated with roads and pipelines, has been
consistently identified as a key concern by the community of Nuiqsut, which relies heavily on caribou for
their sustenance and is located closest to the Project.
Furthermore, disapproving BT5, in lieu of deferring it (as described in Alternative E of the Supplemental
EIS), reduces the overall period of construction activities, which tend to involve more intense impacts to
subsistence activities and wildlife including caribou. The Final Supplemental EIS assumed BT5
construction in Year 7 to be the most impactful scenario under Alternative E because it would have the
most overlap between the construction of BT5 and drilling phases at BT1, BT2, and BT3. Disapproving
BT5 reduces the severity and intensity of the impacts due to there being less overall Project activity (i.e.,
other construction and drilling activity) and eliminates the most impactful scenario under Alternative E as
analyzed in the Final Supplemental EIS; that is, the most overlap between the construction of BT5 and
drilling phases at BT1, BT2, and BT3.
Disapproving BT4 and BT5 also reduces the Project’s direct and indirect greenhouse gas emissions, better
enabling the United States to reach its economy-wide target of reducing its net greenhouse gas emissions
by 50% to 52% below 2005 levels by 2030 pursuant to its commitment under the Paris Agreement
(UNFCCC 2021).
This decision strikes a balance, allowing for development to occur in the NPR-A consistent with the terms
of existing leases while at the same time requiring the implementation of robust protections for surface
resources, as well as measures to limit greenhouse gas emissions and thereby reduce climate impacts.
The latter is especially important in the NPR-A, given the significant effects of climate change on the
Arctic and the North Slope (see Section 3.2.1 of the Final Supplemental EIS). In the expanded range of
alternatives considered in the Final Supplemental EIS, BLM has directly addressed the direction of the
U.S. District Court to reassess the range of alternatives. Alternative E, both as presented in the Final
Supplemental EIS and also as modified in this Decision, produces less oil than Alternatives B, C, and D
and also does not afford ConocoPhillips the right to extract “all possible” oil and gas on its leases. By
adopting Alternative E as modified, therefore, the BLM has not only selected an alternative that results in
fewer overall greenhouse gas emissions, but the agency has also given effect to the Court’s direction.
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As reflected in the Final Supplemental EIS, Table D.4.8 (Appendix D.1, Alternatives Development),
under Alternative B (Proponent’s Project) the estimated total oil and non-gas liquids production would be
628.9 million barrels, with associated indirect CO2e emissions of 260,790,000 metric tons (Section
3.2.2.6). Under Alternative E, total oil and non-gas liquids production for development of all four drill
sites (BT1, BT2, BT3 and BT5) is 613.5 million barrels, with associated indirect CO2e emissions of
254,391,000 metric tons. Thus, under Alternative E as described in the Final Supplemental EIS, the
elimination of BT4 results in 15.4 million barrels (2.45%) less production relative to Alternative B and a
total reduction of indirect CO2e emissions of 6,399,000 metric tons.
As reflected in Section 3.2.2.6 of the Final Supplemental EIS, under Alternative E as modified in this
Decision, total production for drill sites BT1, BT2 and BT3, without the contribution of the disapproved
drill site BT5, is approximately 576.0 million barrels with associated indirect CO2e emissions of
239,040,000 metric tons; this is 52.9 million barrels (8.4%) less production relative to Alternative B and a
total reduction of indirect CO2e emissions of 21,750,000 metric tons.
Under Alternative E as approved in this Decision [BT1, BT2 and BT3 approved; BT5 disapproved], the
Project would produce approximately 94% of the total production for Alternative E as analyzed in the
Final Supplemental EIS, which included production from BT5. More specifically, drill site BT1 would
produce approximately 295.6 million barrels, which is approximately 48% of the total production for
Alternative E as analyzed, with associated indirect CO2e emissions of 122,674,000 metric tons. Drill site
BT2 would produce approximately 143.6 million barrels, which is approximately 23% of the total
production for Alternative E as analyzed, with indirect CO2e emissions of 59,594,000 metric tons. Drill
site BT3 would produce approximately 136.8 million barrels, which is approximately 22% of the total
production for Alternative E as analyzed, with indirect CO2e emissions of 56,772,000 metric tons.
Disapproved drill site BT5 would have produced approximately 37.5 million barrels, or approximately
6% of the total production under Alternative E as analyzed, with associated indirect CO2e emissions of
15,562,500 metric tons.
In accordance with ANILCA Section 810, the Decision adopted in this ROD also addresses local
residents’ concerns regarding protection of their subsistence way of life and the subsistence resources on
which they depend through the application of numerous lease stipulations, ROPs, design features, and
new mitigation measures that provide protection for subsistence resources and uses, as well as through the
disapproval of drill sites BT4 and BT5 and their associated roads and pipelines. The Project will facilitate
subsistence activities for local subsistence users by including three subsistence boat ramps and up to
seven vehicle turnouts with subsistence/tundra access ramps and affording additional road access.
The Project will lead to increased revenues for the State of Alaska and NSB resulting from federal
royalties and state and local taxes potentially up to $10 billion as well as increased federal revenues
potentially up to $7 billion (see Final Supplemental EIS Table 3.15.5, Summary of State, Federal, and
Borough Revenues from the Project). Pursuant to the NPRPA, 50% of royalties from the production of oil
and gas on federal lands in the NPR-A is paid to the State of Alaska. Local residents and communities
impacted by the Project will benefit indirectly from revenues associated with the development on
federally managed lands that would accrue to the State of Alaska. Under the NPRPA, in allocating its
50% share of federal revenues from oil and gas development on federal lands in the NPR-A, the State
must give priority consideration to use by those communities most impacted by such development, which
it does through its NPR-A Impact Grant Program. Construction of Project facilities would occur over
approximately 8 years and employ up to 1,733 seasonal workers (peak). During the project drilling phase,
up to 400 annual workers would be employed. Up to 450 annual workers would be employed during the
Project’s operational phase (see Final Supplemental EIS Tables 3.15.6-8).
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5.0 PUBLIC INVOLVEMENT

Public involvement is an integral part of the NEPA process and is required in the preparation and
implementation of agencies’ NEPA procedures. Public involvement provided an opportunity for the
public and agencies to express their views and help identify issues to be addressed in the Supplemental
EIS and to provide comments on the Draft Supplemental EIS.
BLM hereby certifies that the agency has considered all of the alternatives, information, analyses, and
objections submitted by State, Tribal, and local governments and public commenters for consideration by
the lead and cooperating agencies in developing the Final Supplement EIS.
5.1 Public Notices

Public Notice dates:
• Notice of Intent: August 8, 2018
• Notice of Availability of Draft EIS: August 20, 2019
• Notice of Availability of Supplemental Draft Environmental Impact Statement (SDEIS): March
26, 2020
• Notice of Availability of Final EIS: August 14, 2020
• Notice of Intent of Supplemental EIS: February 7, 2022
• Notice of Availability of Draft Supplemental EIS: July 15, 2022
• Notice of Availability of Final Supplemental EIS: February 3, 2023
Public Notice periods:
• Public scoping: August 8, 2018, to September 30, 2018
• Public comment on Draft EIS: August 30, 2019, to October 29, 2019
• Public comment on SDEIS: March 26, 2020, to May 4, 2020
• Informal scoping period on Supplemental EIS: February 7, 2022, to March 9, 2022
• Public Comment on Draft Supplemental EIS: July 15, 2022, to August 29, 2022
5.2 Previous Public Involvement

Previously, the Federal Register published an initial Notice of Intent to prepare an EIS (83 FR 38725) on
August 8, 2018. An open scoping period was held from August 8, 2018, through September 30, 2018. On
August 30, 2019, a Notice of Availability of the Draft EIS was published in the Federal Register (84 FR
45801) announcing the public comment period for the Draft EIS, which ended on October 29, 2019.
Public meetings for the Draft EIS were held in September and October 2019. On March 26, 2020, a
Notice of Availability of the SDEIS was published in the Federal Register (85 FR 17094) announcing the
public comment period for the SDEIS, which ended on May 4, 2020. Public meetings for the SDEIS were
held online and via telephone on April 16, 21, and 23, 2020.
BLM published the Project documents on its website (https://eplanning.blm.gov/eplanning-ui/project/
109410/510) to provide information, maps, and documents for the public about the Project and the NEPA
process and to give meeting notices. The website also provided links to other useful online resources.
5.3 Public Involvement for the Supplemental EIS

The Federal Register published a Notice of Intent to prepare a Supplemental EIS (87 FR 6890) on
February 7, 2022. An informal scoping period was held from February 7, 2022, through March 9, 2022, to
gather public and stakeholder input regarding the Project. Comment submissions and issues raised
informed the analysis in the Supplemental EIS.
On July 15, 2022, a Notice of Availability of the Draft Supplemental EIS was published in the Federal
Register announcing a 45-day public comment period for the Draft Supplemental EIS, which ended on
Page 13
August 29, 2022. The public meeting process held during the comment period provided the opportunity
for potentially affected and interested individuals, agencies, and groups to help:
• Share information and identify concerns about the new Alternative E
• Define a range of alternatives
• Determine and define the scope of issues to examine
• Identify other environmental and consultation requirements
• Gather additional information regarding potential effects of the Proposed Action
• Inform and identify potentially interested parties
The BLM held public meetings (virtual and in-person) on the Draft Supplemental EIS in August 2022.
Details concerning dates, times, and locations of the meetings were announced through local news media,
newspapers, and the BLM Project ePlanning website. Verbal comments given at public meetings and the
public hearing were documented in formal transcripts for each individual meeting. Comments on the
Draft Supplemental EIS were received via email and mail, via the ePlanning website, and at public
meetings. The presentation used during the meetings, transcripts of each meeting, public and agency input
received during the public process, and a summary scoping report are available on the BLM Willow MDP
ePlanning website: https://eplanning.blm.gov/eplanning-ui/project/109410/510.
• August 08, 2022 - Virtual • August 18, 2022 - Virtual
• August 15, 2022 - Virtual • August 22, 2022 - Utqiaġvik
• August 16, 2022 - Nuiqsut • August 24, 2022 - Virtual
• August 17, 2022 - Virtual
The Nuiqsut meeting included the public hearing for comments regarding the Project’s potential impacts
to subsistence resources and activities as per the ANILCA Section 810.
On February 3, 2023, the U.S. Environmental Protection Agency published a Notice of Availability of the
Final Supplemental EIS in the Federal Register (88 FR 7445), initiating a 30-day pre-ROD waiting
period that ended on March 6, 2023.
5.4 Evaluation and Consideration of Comments Received

Numerous comments were received from local, state, and federal agencies, Tribes, and the public on the
Draft Supplemental EIS during the comment period which ran from July 15, 2022, to August 29, 2022.
Comments received on the Draft Supplemental EIS are summarized, and responses provided, in Appendix
B.5 of the final Supplemental EIS (Draft Supplemental EIS Comments and BLM Responses).
The BLM received a total of 218,931 submissions during the public comment period via email, online, or
mailed-in letters, or comments submitted verbally at public meetings. Of the submissions, 4,440 were
unique (i.e., original submissions that did not have identical or almost identical wording as another
submission). The remaining submissions were form letters (i.e., submissions containing identical
content), form letters with slight modifications (e.g., one or two unique sentences added, but otherwise
identical to a form letter), or duplicate submissions (i.e., the sender submitted the same submission
multiple times). In total, 817 individual substantive comments were identified from the various letters and
verbal testimonies and categorized, Final Supplemental EIS, Appendix B.2, Table B.2.4. Just over half of
all comments (52%) fell into the following top seven categories: mitigation or minimization, climate
change, request for extension or for no extension of public comment period, alternatives, cumulative
effects, marine mammals, and EIS process/timeline.
5.4.1 Comments Received Prior to the Final Supplemental EIS

The BLM received a number of submissions after the formal 45-day comment period on the Draft
Supplemental EIS concluded on August 29, 2022. All submissions received outside of the formal
comment period but prior to the publication of the Final Supplemental EIS on February 1, 2023 were
Page 14
considered in the same manner as those comments received during the formal comment period. All
substantive comments identified were reviewed by subject matter experts, and new information and
citations were incorporated into the Final Supplemental EIS as appropriate.
5.4.2 Comments Received After the Final Supplemental EIS

After the Final Supplemental EIS was published (February 1, 2023), the BLM received and considered
comments and additional information submitted to the BLM by the public and various stakeholders.
Submissions were received via email, phone call, and hard copy letter. These comments were generally
similar to and consistent with the comments received during the development of the Supplemental EIS.
The majority of comments received were non-substantive, expressing either opposition to or support for
the Willow MDP Project. Some comment submissions were substantive, providing specific input
regarding the Final Supplemental EIS, which the BLM has included in the decision file and considered
prior to executing this ROD.
The BLM reviewed all comment submissions received after the release of the Final Supplemental EIS to
determine if the information presented significant new circumstances or information relevant to
environmental concerns and bearing on the proposed action or its impacts, consistent with 40 CFR
1502.9(d). As a result of that review, the BLM finds that existing analysis in the Final Supplemental EIS
remains adequate and does not require supplementation.
During its review of comments and additional information received following the publication of the Final
Supplemental EIS, the BLM realized a need to clarify its response to comment #6501-320 in Appendix
B.5, Draft Supplemental Environmental Impact Statement Comment Report (p. 20) concerning the
evaluation of emissions associated with construction activities of drill site BT5 under Alternative E. As
such, the following clarification is provided:
The Final Supplemental EIS includes quantitative modeling and emissions for Alternative E. The
Final Supplemental EIS calculated and reported construction emissions for all pads, including
BT5. As noted in the Air Quality Technical Support Document (AQTSD) (Appendix E.3B, Final
Supplemental EIS), the annual criteria pollutant emissions totals during construction phases are
expected to peak during Year 4 of the Project when concurrent activities occur during
construction of WPF, Willow Operation Center, BT1 drill site, BT2 drill site, BT3 drill site along
with installation of major pipeline and roads/bridges. Thus, these activities were conservatively
modeled for the construction activities in Alternative E.
The Final Supplemental EIS also includes quantitative modeling for a "Development Drilling"
scenario that evaluated impacts associated with concurrent operations of BT5 and other pads,
drilling at BT2 and BT3, and construction of facility installations of BT1, BT2, BT3, and WCF,
and construction of pipeline and vertical support members. This scenario represents an estimate
of the combined impacts that could occur from production and construction activities during
drilling if concurrent operations were to occur. Modeled impacts for Alternative E for the
“Development Drilling” scenario were below the NAAQS (impacts ranging from 3% to 84% of
the NAAQS) anywhere in the analysis area. Thus, any slight changes to emissions modeled
would not materially impact the conclusions. Modeled impacts for Alternative E for other
scenarios are also below applicable thresholds for all pollutants.
The Alternative E near-field modeling approach, input data, model configurations, emissions
processing methods, and results are documented in Attachment H to the AQTSD.
5.5 Engagement with Environmental Justice Communities

BLM Instruction Memorandum 2022-059, Environmental Justice Implementation, directs BLM to
“…proactively provide opportunities for meaningful involvement of minority populations, low-income
populations, and Tribes in BLM decision making processes that affect their lives, livelihoods, and health.
Page 15
This commitment is in addition to the BLM’s responsibilities to consult with federally recognized Tribes
and Alaska Native Corporations, as outlined in Department and BLM policies.”
During development of the Supplemental EIS, BLM engaged with multiple Alaska Native entities on the
North Slope to seek input on the Project and how it may impact environmental justice populations. These
consultations provided community members the opportunity to engage with BLM to provide their
comments on the Project and offer suggestions on how Project impacts may be avoided or minimized, or
potential mitigation measures that may reduce Project impacts for Alaska Native stakeholders. The Final
Supplemental EIS, Table 3.17.2 Summary of BLM’s Alaska Native Consultation Meetings for the Willow
Supplemental Environmental Impact Statement, provides an overview of BLM’s consultation efforts with
Alaska Native entities during development of the Supplemental EIS. It includes cooperating agency
meetings where the City of Nuiqsut, Native Village of Nuiqsut, or Inupiat Community of the Arctic Slope
attended, as well as meetings with North Slope entities that included numerous community
representatives, the North Slope Resource Advisory Council meetings, and NPR-A Working Group
meetings.
Information presented during public meetings and public comments, consultations, cooperating agency
meetings, government to government consultations and other stakeholder meetings was used to develop
the range of alternatives and identify potential impacts to environmental justice populations. The
Alternative and mitigation measures chosen in this ROD address in part the comments from the
community of Nuiqsut and entities from Nuiqsut to further protect the caribou herd in the TLSA. This
information was also incorporated into the resource analyses for subsistence and sociocultural systems,
terrestrial mammals, public health, economics, and environmental justice. Commenters also suggested
mitigation measures that could reduce the impacts of the Project. Potential mitigation measures that were
developed in response to community concerns are included in the Final Supplemental EIS Table 3.17.3,
Mitigation Measures Proposed for the Willow Supplemental Environmental Impact Statement to Reduce
Impacts to Environmental Justice Populations.
6.0 RELATED LAWS AND POLICIES

6.1 Alaska National Interest Lands Conservation Act
ANILCA Section 810 provides that no public land use, occupancy, or disposition which would
significantly restrict subsistence uses shall be effected until the authorizing federal agency gives the
required notice and holds a hearing in accordance with ANILCA Section 810(a)(1) and (2) and makes the
three determinations required by ANILCA Section 810(a)(3)(A), (B), and (C). The three determinations
that must be made are that 1) such a significant restriction of subsistence use is necessary and consistent
with sound management principles for the use of public lands; 2) the proposed activity will involve the
minimal amount of public lands necessary to accomplish the purposes of such use, occupancy, or other
such disposition; and 3) reasonable steps will be taken to minimize adverse impacts to subsistence uses
and resources resulting from such action (16 USC 3120(a)(3)(A), (B), and (C)).
The ANILCA Section 810 analysis and findings are included in Final Supplemental EIS Appendix G,
Alaska National Interest Lands Conservation Act Section 810 Analysis and are briefly summarized here.
BLM’s findings conclude that for all action alternatives analyzed in the Final Supplemental EIS the
Project is not expected to result in a large reduction in the abundance (population level) of caribou or any
other subsistence resource. However, the evaluation concludes that the Project may significantly restrict
subsistence uses for the community of Nuiqsut due to a reduction in the availability of resources caused
by the alteration of their distribution and the limitation on subsistence user access to the area. Module
Delivery Option 3, in combination with Alternative E as modified herein, would not result in any
additional significant restriction of subsistence uses for communities in or near the Project area.
Page 16
BLM’s findings conclude that the cumulative effects of current and future activities may significantly
restrict subsistence uses for Nuiqsut due to a reduction in availability of caribou and furbearers and due to
limitations on subsistence user access to the area.
Because the final ANILCA Section 810 evaluation in the Final Supplemental EIS concluded that BLM’s
preferred alternative, Alternative E, may significantly restrict subsistence uses, including in the
cumulative case, BLM is required to make the three determinations required by ANILCA Section
810(a)(3)(A), (B), and (C). BLM’s determinations are included in Appendix B of this ROD.
6.2 Endangered Species Act

Section 7(a)(2) of the ESA requires federal agencies to consult with USFWS and National Marine
Fisheries Service (NMFS), as appropriate, to ensure that their actions do not jeopardize the continued
existence of species listed as threatened or endangered under the ESA or destroy or adversely modify
their critical habitat. Pursuant to Section 7 of the ESA (16 USC 1531 et seq.), BLM consulted with both
NMFS and USFWS on ESA-listed species that may occur within the action area.
On January 13, 2023, in its Biological Opinion, USFWS determined that the Project may affect, but is not
likely to adversely affect Alaska-breeding Steller’s eiders, the southwest Alaska DPS of northern sea
otters, or critical habitat for these two species. USFWS determined the effects of the Project are not
reasonably likely to jeopardize the continued existence of spectacled eiders or polar bears or result in the
destruction or adverse modification of any unit of critical habitat for these two species.
On March 2, 2023, in its Letter of Concurrence, NMFS concurred with BLM’s determination that the
Project may affect, but is not likely to adversely affect: the bowhead whale, blue whale, fin whale, North
Pacific right whale, Western North Pacific DPS gray whale, Western North Pacific distinct population
segment (DPS) or Mexico DPS humpback whale, sperm whale, Arctic subspecies ringed seal, Beringia
DPS bearded seal, or the Western DPS Steller sea lion. NMFS also concurred with the BLM’s
determination that the Project would not destroy or adversely modify critical habitat for the North Pacific
right whale, Western North Pacific or Mexico DPS humpback whale, Arctic subspecies ringed seal,
Beringia DPS bearded seal, or Steller sea lion.
6.3 Clean Air Act

The Clean Air Act (CAA) (42 USC 7401–7671 Section 176(c)) General Conformity Rule review was
carried out. The proposed permit action is not in a CAA non-attainment area, and the conformity
determination requirements of the CAA would not apply to the Project at this time. Any later indirect
emissions generally cannot be practicably controlled by BLM. For these reasons, a conformity
determination is not required for this action.
6.4 Clean Water Act

Pursuant to Section 401 of the CWA (33 USC 1341), a Section 404 CWA permit is not valid until a
Section 401 Water Quality Certification (WQC) has been issued or the requirement for the certification
has been waived. For the purposes of the Project, the State of Alaska administers Section 401 WQC.
Conditions of the Section 401 WQC would become conditions of the final U.S. Department of the Army
permit.
6.5 Coastal Zone Management Act

By operation of Alaska State law, the federally approved Alaska Coastal Management Program expired
on July 1, 2011, resulting in a withdrawal from participation in the Coastal Zone Management Act’s (16
USC 1456(C)) National Coastal Management Program. The Coastal Zone Management Act federal
consistency provision, Section 307, no longer applies in Alaska. The Federal Register Notice was
published July 7, 2011 (76 FR 39857).
Page 17
6.6 Fish and Wildlife Coordination Act

The Migratory Marine Game-Fish Act (16 USC 760c–760g), the Fish and Wildlife Coordination Act (16
USC 661–666c), and other acts express the will of the U.S. Congress to protect the quality of the aquatic
environment as it affects the conservation, improvement, and enjoyment of fish and wildlife resources.
Under the Fish and Wildlife Coordination Act, any federal agency that proposes to control or modify any
body of water must first consult with USFWS or NMFS, as appropriate, and with the head of the
appropriate state agency exercising administration over the wildlife resources of the affected state.
Coordination with USFWS, NMFS, and the State of Alaska Department of Fish and Game and
completion of the process and analyses contained within the Final Supplemental EIS and ROD is
required. A signature by the authorizing official completes BLM’s Fish and Wildlife Coordination Act
responsibilities.
6.7 Materials Act

Pursuant to 43 CFR 3601.3, BLM’s authority to dispose of sand, gravel, and other mineral and vegetative
materials that are not subject to mineral leasing or location under mining laws is the Act of July 31, 1947,
as amended (30 USC 601 et seq.), commonly referred to as the Materials Act. In the NPR-A, the BLM is
authorized to dispose of mineral materials as necessary to carry out the NPRPA. (43 USC 6502). This
authority applies to the sale and free use of these materials. Mineral materials disposal is managed under
BLM regulations at 43 CFR 3600. Under these regulations, site-specific mining and reclamation plans are
required before BLM can permit specific disposal actions.
6.8 Magnuson-Stevens Fishery Conservation and Management Act

Section 305(b)(2) of the Magnuson-Stevens Fishery Conservation and Management Act requires federal
agencies to consult with NMFS on any action authorized, funded, or undertaken that may adversely affect
Essential Fish Habitat (EFH). Marine EFH occurs throughout the Beaufort Sea for pink salmon, chum
salmon, Chinook salmon, sockeye salmon, coho salmon, saffron cod, and Arctic cod. The Project could
affect marine EFH due to screeding at Oliktok Dock and the barge lightering area.
EFH is assessed in Section 3.10 (Fish) of the Final Supplemental EIS. The EFH assessment that describes
the Project’s potential adverse effects on EFH in accordance with the Magnuson-Stevens Fishery
Conservation and Management Act has been reviewed by NMFS and its concurrence is in the
administrative record.
6.9 Mineral Leasing Act

Under Section 28 of the MLA (30 USC 185) and 43 CFR Part 2880, BLM has the authority to issue ROW
grants for oil or natural gas pipelines or related facilities to cross BLM-managed public lands. In the
NPR-A, the Secretary of the Interior acting through the BLM is authorized to issue such rights-of-way as
necessary to carry out the NPRPA. (43 USC 6502). The Proponent would need to obtain a ROW grant
and temporary use permits from BLM for crossing BLM-managed lands. In addition, Section 28(p) of the
MLA, 30 USC 185(p), requires BLM to consider the colocation of ROWs to the extent practicable in
order to minimize adverse environmental impacts.
6.10 National Historic Preservation Act

Section 106 of the National Historic Preservation Act (NHPA) requires each federal agency, prior to any
federal or federally assisted or funded undertaking, to take into account the effect of its proposed
undertaking on any property included in or eligible for the National Register of Historic Places (NRHP)
(hereafter called historic properties).
Consultation under NHPA Section 106 the Willow Supplemental EIS process was initiated on January 13,
2023, with the Alaska State Historic Preservation Office. BLM, as the lead federal agency for Section 106
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obligations under the NHPA, and in consultation with the State Historic Preservation Officer (SHPO), the
Alaska Department of Natural Resources, the Advisory Council on Historic Preservation, and the
Proponent, has established the undertaking's area of potential effects (APE), as defined in 36 CFR
800.16(d), which encompasses direct and indirect effects on historic properties for alternatives carried
forward for detailed analysis in the Final Supplemental EIS. The APE applies to all lands, regardless of
management status, that may be affected by the mine site, pipeline corridor, transportation system, staging
areas, access roads, or other infrastructure related to the Project undertaking.
BLM has completed coordination and consultation pursuant to Section 106 of the NHPA (16 USC 470 et
seq.). The Project would not adversely affect sites listed in, or eligible for listing in, the NRHP or of other
national, state, or local significance. Consultation under and compliance with Section 106 of the NHPA
have been concluded.
6.11 Executive Order 11988 (Floodplain Management)

Executive Order (EO) 11988 requires an agency to provide leadership and to take action to minimize the
impact of floods on human safety, health, and welfare and to restore and preserve the natural and
beneficial values served by floodplains in carrying out its responsibilities. In carrying out activities
required by EO 11988, the agency has the following responsibilities:
1. Evaluate the potential effects of any actions that may take place in a floodplain
2. Ensure that its planning programs and budget requests reflect consideration of flood hazards
and floodplain management
Prescribe procedures to implement the policies and requirements of EO 11988 Additional requirements
are as follows:
1. Before taking an action, each agency shall determine whether the Proposed Action will occur
in a floodplain and the evaluation required will be included in the EIS prepared under NEPA.
2. If an agency has determined to, or proposes to, conduct, support, or allow an action to be
located in a floodplain, the agency shall consider alternatives to avoid adverse effects and
incompatible development in the floodplain. If the head of the agency finds that the only
practicable alternative consistent with the law and with the policy set forth in this EO requires
siting in a floodplain, the agency shall, prior to taking action,
a. Design or modify its action in order to minimize potential harm to or within the
floodplain, consistent with regulations, and
b. Prepare documentation explaining why the action is proposed to be located in the
floodplain.
The Project would place gravel fill in the 50- or 100-year floodplains of Fish Creek, Judy (Kayyaaq)
Creek, Judy (Iqalliqpik) Creek, Willow Creek 2, Willow Creek 8, and the Ublutuoch (Tiŋmiaqsiuġvik)
River, as described in Section 3.8.2.6 of the Final Supplemental EIS.
The long-term effects, both direct and cumulative, on floodplains of ConocoPhillips’s development on
BLM-managed lands, as approved in this ROD, are expected to be minor and would be mitigated to the
greatest extent practicable. Similar to wetlands, total avoidance of floodplains is impossible due to the
geography and hydrologic features of the area.
This decision avoids and minimizes impacts to floodplains by siting facilities to avoid unnecessary stream
crossings and by incorporating design features (such as siting the mine pits, multi-season ice pads, and
most of the single- season ice pads outside the floodplain) to minimize impacts. The Project will use
bridges at larger stream crossings and culverts at smaller stream crossings.
Although the floodplain at most of the stream crossings is limited to a narrow area, the floodplains of Fish
Creek and Judy (Iqalliqpik) Creek are wider and would encompass the gravel road on either side of the
crossing. These two streams would also have boat ramps constructed in their floodplains. If gravel roads,
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pads, or boat ramps block or restrict the flow of surface water during spring breakup, they may: 1)
increase the depth and duration of water impoundment, 2) increase thermokarsting, 3) cause a change in
flow direction, 4) cause channel instability or a change in alignment, 5) result in erosion of the tundra or a
stream channel, or 6) result in deposition of sediment on the tundra or in a stream channel. Effects 1
through 3 would occur on the upstream side of the road or pad; Effects 4 through 6 could occur on either
the upstream or the downstream side of the road or pad. If the blockages were fixed within the year in
which they were first observed, did not overtop the road or pad, and did not drain along the upstream side
of the road, the resulting impact of the blockage would be measurable but would not require
rehabilitation. However, thermokarsting due to water impoundments resulting from blockages would
create a depression that would last indefinitely. If the blockage caused a change in flow direction, channel
instability, or erosion of the tundra or stream channel, or resulted in deposition of sediment on the tundra
or in the stream channel, the impact would be measurable and require rehabilitation. The impact could be
visible for many years, even with rehabilitation.
ROP E-3 requires that culverts maintain free passage of marine and anadromous fish. CPAI will be
required to provide annual surveillance of bridge, culvert, and pipeline river crossings for the first 3 years
to confirm that structures are functioning properly and to provide maintenance as required and at least
once every 3 years thereafter.
Specific measures to protect water resources include requirements that roads, pipelines, and water
crossings be designed to maintain existing hydrology, including during flood periods. Also, gravel roads,
culverts, and bridges must be designed with erosion control mechanisms. In addition to BLM lease
stipulations and ROPs, Project activities that could impact water resources will be subject to federal, state,
and local permit requirements. Thus, the facilities authorized in this ROD will avoid impacts to
floodplains to the maximum extent practicable and will have minimal to negligible impacts on the
functions and values of floodplains.
6.12 Executive Order 11990 (Wetlands)

EO 11990 requires that BLM consider factors relevant to the Project’s effect on the survival and quality
of wetlands. Factors to be considered include the following:
• Public health, safety, and welfare, including water supply, quality, recharge, and discharge;
pollution; flood and storm hazards; and sediment and erosion
• Maintenance of natural systems, including conservation and long-term productivity of existing
flora and fauna, species and habitat diversity and stability, hydrologic utility, fish, wildlife,
timber, and food and fiber resources
• Other uses of wetlands in the public interest, including recreation and scientific and cultural uses
BLM is required to avoid undertaking or providing assistance for new construction located in wetlands
unless the head of the agency finds
1. there is no practicable alternative to such construction and
2. the Proposed Action includes all practicable measures to minimize harm to wetlands that may
result from such use. In making this finding, the head of the agency may take into account
economic, environmental, and other pertinent factors.
Project facilities will be located entirely on the Arctic coastal plain, as depicted in Figure 3.9.2 of the
Final Supplemental EIS. Wetlands occupy 94% of the field-verified wetlands analysis area (the Willow
area), and freshwater waters of the U.S. occupy an additional approximate 5% (Table 3.9.1 of the Final
Supplemental EIS). The most common wetland type in the wetland analysis area is Palustrine Emergent
Persistent/Scrub-Shrub Broad- Leaved Deciduous Seasonally Saturated (31% of the analysis area). Table
E.9.1 in Final Supplemental EIS, Appendix E.9 (Vegetation and Wetlands) demonstrates that wetland
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types in the field-verified wetlands analysis area are not unique and occur throughout the analysis area
and the Arctic Coastal Plain.
Alternative E as modified [BT1, BT2 and BT3 approved; BT5 disapproved] and Module Delivery Option
3 will result in wetland loss due to gravel fill or excavation (Table E.9.2 in Appendix E.9 of the Final
Supplemental EIS), direct vegetation damage and soil compaction from ice infrastructure (Table E.9.5 in
Appendix E.9 of the Final Supplemental EIS), and indirect changes to wetland composition due to dust
and gravel spray (Table E.9.6 in Appendix E.9 of the Final Supplemental EIS). Loss of wetlands and
changes to wetland composition will be long term; vegetation damage and soil compaction will be short
to medium term depending on the degree of saturation of soils. Because virtually the entire Arctic Coastal
Plain consists of wetlands, it is not possible to produce the oil reserves on ConocoPhillips’s leases without
impacting wetlands.
Wetlands impacts will be mitigated through BLM lease stipulations, ROPs, and design features, listed in
Appendix A of this ROD. These include measures regarding the following:
• Waste management, spill prevention and response, and hazardous materials emergency
contingency plans
• Winter travel and protection of soil, vegetation, and streams
• Facility design and requirements that permanent facilities minimize footprint
• Timing of extraction of gravel and construction of gravel roads, pads, and pipelines to use ice
roads, thus minimizing potential impacts to wetlands
• Dust control
• Incorporation of the findings of fish surveys and hydrologic modeling into the design of bridges
and culverts
Because of these mitigation measures, no significant impacts are expected that would affect public health,
safety, and welfare through changes in the supply, quality, recharge or discharge, and pollution of water
or flood and storm hazards or sedimentation and erosion.
Therefore, BLM finds that there is currently no practicable alternative to construction of the Project in
wetlands and that all practicable measures to minimize harm to wetlands have been taken, given the
technical, economic, and environmental factors that must be weighed.
6.13 Executive Order 13112 (Invasive Species)

Invasive species are addressed in accordance with EO 13112 in Sections 3.9 (Wetlands and Vegetation),
3.10 (Fish), 3.13 (Marine Mammals), and 3.20 (Cumulative Effects) of the Final Supplemental EIS.
6.14 Executive Order 12898 (Environmental Justice)

EO 12898 directs federal agencies to take appropriate and necessary steps to identify and address
disproportionately high and adverse effects of federal decisions on the health or environment of minority
and low-income populations to the greatest extent practicable and permitted by law. See Section 3.17
(Environmental Justice) of the Final Supplemental EIS.
For all action alternatives, the Final Supplemental EIS identified adverse impacts to the community of
Nuiqsut, which meets the demographic characteristics to be qualified as a minority population. Impacts to
subsistence and sociocultural systems that were considered in the finding of impacts for environmental
justice were decreased resource availability and decreased harvester access (Section 3.17.6 of the Final
Supplemental EIS).
Resource availability could decrease due to loss or alteration of habitat for birds, fish, caribou, and other
terrestrial mammals; disturbance or displacement of animals; or direct injury or mortality. However, the
decrease would not have population-level effects on subsistence resources harvested within or
downstream from the Project area.
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Harvester access would be adversely affected by the construction of roads through areas used for
harvesting wolf, wolverine, caribou, and geese. As noted in Section 3.16, Subsistence and Sociocultural
Systems, of the Final Supplemental EIS, at least one-third of harvesters that use the Project area are likely
to avoid the affected area during at least 1 year during construction. During operations, harvester access
would be adversely affected by roads through areas used for harvesting. Some Nuiqsut caribou hunters
use trucks to access subsistence harvest areas and may use roads constructed under this alternative. This
could increase competition along the road and deflect caribou from the community’s traditional harvest
area, reducing success for those continuing to use traditional areas. Some subsistence harvesters also
avoid developed areas due to concerns about security protocols and an assumed lack of resources around
these areas.
The effects on subsistence and sociocultural systems may be highly adverse and disproportionately borne
by the Nuiqsut population.
Impacts to public health that were considered in the finding of impacts for environmental justice were
Project employment opportunities and dividend income, increased stress, and impacts to subsistence
(Section 3.17.3.3.3, Public Health, of the Final Supplemental EIS). The Project would result in additional
employment opportunities in Nuiqsut. Although most construction jobs would be filled by non-locals,
even a small number of additional jobs would positively impact the community’s relatively small labor
force. Project construction would increase household incomes for Nuiqsut residents employed with the
Project, and dividend income would also increase for Arctic Slope Regional Corporation and Kuukpik
shareholders if these corporations have subsidiaries working on the Project.
Not all Nuiqsut residents would find jobs or receive Alaska Native Claims Settlement Act corporation
dividends, resulting in the potential for social tensions regarding an uneven distribution of money in the
community. The Project would increase air and noise emissions and human activity in Nuiqsut’s
subsistence use area. This could increase stress in some Nuiqsut residents and lead to or exacerbate
mental health issues such as anxiety and depression. As discussed in BLM (2018), rapid modernization
and development, as well as other multiple stressful conditions, including significant changes in diet,
housing, and traditional culture, has led to negative health outcomes, including suicide.
Reduced subsistence harvester access or subsistence resource availability would adversely affect
community health by reducing the availability of subsistence foods and increasing the dependence on
store-bought foods, increasing food insecurity. Among all NSB communities, a higher percentage of
Nuiqsut households use subsistence resources for more than half of their diet (NSB 2016).
The effects on public health in Nuiqsut may be highly adverse and disproportionately borne by the
Nuiqsut population.
In addition to the direct and indirect effects of the Project on environmental justice, the cumulative effects
of the Project (considered in combination with past and future projects) on subsistence, sociocultural
systems, and public health may be highly adverse and would be disproportionately borne by populations
from Nuiqsut, Utqiaġvik, Anaktuvuk Pass, Atqasuk, Point Lay, and Wainwright. These effects are
described in Section 3.20.15, Cumulative Impacts to Environmental Justice, of the Final Supplemental
EIS and would be long term and of high intensity.
Stipulations in the federal leases and ROPs avoid or mitigate many of these impacts. Relevant stipulations
include, but are not limited to, those that require ready access to spill cleanup materials, minimization of
flights in the Project area during the peak caribou hunting period, spill response training, the separation
distance between roads and pipelines (reducing the potential of combined facilities to obstruct caribou
movement), and consultation with subsistence users.
The Project’s existing mitigation measures, design features, and additional mitigation measures contribute
to avoiding, minimizing, or mitigating impacts to subsistence and public health, including, but not limited
to the following:
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• Using a non-reflective finish on all pipelines

• Establishing speed limits, pull-outs, and caravanning requirements on Project roads
• Minimizing helicopter flights during peak caribou harvesting periods
This Decision's disapproval of drill sites BT4 and BT5 will further reduce effects of the Project on
subsistence and sociocultural systems and public health borne by the Nuiqsut population. In particular,
the disapproval of BT4 (proposed to be in the TLSA) will nearly cut in half the proposed development in
the TLSA, thereby reducing impacts on caribou and the community’s subsistence harvest of caribou.
Additionally, by disapproving the farthest north and south pads, the Decision addresses community
concerns regarding development encircling their community.
6.15 Executive Order 13175 (Consultation and Coordination with Indian

Tribal Governments)
BLM conducted government-to-government consultation with Tribes and Alaska Native Claims
Settlement Act consultation with Alaska Native Corporations in accordance with EO 13175. See Sections
1.10.4 (Native Consultation) and 3.17.2 (Meaningful Engagement), of the Final Supplemental EIS.
7.0 OTHER AUTHORIZATIONS

For other state and local authorizations that apply to the Project, see Appendix C of the Final
Supplemental EIS.
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8.0 FINAL AGENCY ACTION

8.1 Bureau of Land Management Recommendation
I recommend approval ofthis ROD to select Alternative E as described herein [BTI, BT2 and BT3
approved; BTS disapproved] and Module Delivery Option 3 (Colville River Crossing), as described
above and subject to the terms and conditions for the Project described in Appendix A of this ROD.
MAR 12 2023
Steven M. Cohn Date
State Director
Bureau of Land Management, Alaska
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8.2 Departmental Approval

I hereby approve this ROD to select Alternative E as described herein [BT1, BT2 and BT3 approved; BT5
disapproved] and Module Delivery Option 3 (Colville River Crossing), subject to the terms and
conditions for the Project described in Appendix A.
My approval constitutes the final decision of the DOI and, in accordance with the regulations at 43 CFR
4.410(a)(3), is not subject to appeal under departmental regulations at 43 CFR 4.
Digitally signed by TOMMY

TOMMY BEAUDREAU BEAUDREAU
Date: 2023.03.12 11:03:30 -04'00'
Tommy P. Beaudreau Date

Deputy Secretary of the Interior
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9.0 REFERENCES
BLM. 2018. Alpine Satellite Development Plan for the Proposed Greater Mooses Tooth Two Development
Project – Final Supplemental Environmental Impact Statement. Anchorage, AK.
_____ 2022. National Petroleum Reserve in Alaska Integrated Activity Plan/Record of Decision.
Anchorage, AK.
North Slope Borough. 2016. NSB 2015 Economic Profile and Census. Barrow, AK.
Page 29
Page 30
Record of Decision

Appendix A
Mitigation Measures
March 2023
Willow Master Development Plan Record of Decision
Table of Contents
1.0 Applicable Lease Stipulations, Required Operating Procedures, and Design Features .................. 1
1.1 Lease Stipulations and Required Operating Procedures ........................................................... 1
1.2 Exceptions to Lease Stipulations and Required Operating Procedures .................................... 1
2.0 Applicable Design Features............................................................................................................. 5
3.0 Additional Mitigation Measures Adopted ..................................................................................... 21
Measure 1: Fugitive Dust Control Plan................................................................................................ 22
Measure 2: Flight Paths ....................................................................................................................... 22
Measure 3: Blasting Hours................................................................................................................... 22
Measure 4: Visual Impact Management .............................................................................................. 23
Measure 5: Project Lighting*............................................................................................................... 23
Measure 6: Culvert, Bridge, and Pipeline Stream Crossings ............................................................... 23
Measure 7: Ice Infrastructure ............................................................................................................... 24
Measure 8: Colville River Horizontal Directional Drilling Crossing Construction............................. 25
Measure 9: Surveillance of Stream Crossings ..................................................................................... 25
Measure 10: Option 3 Colville River Crossing Data and Adaptive Management Plan ....................... 25
Measure 11: Boat Ramps Maintenance Plan ....................................................................................... 25
Measure 12: Terrestrial Invasive Species Protections ......................................................................... 26
Measure 13: Overwintering Fish Habitat ............................................................................................. 26
Measure 14: Aquatic Invasive Species Prevention .............................................................................. 26
Measure 15: Bird Collisions* .............................................................................................................. 27
Measure 16: Bird Disturbance* ........................................................................................................... 27
Measure 17: Caribou Crossings* ......................................................................................................... 27
Measure 18: Aircraft Use Plan ............................................................................................................. 28
Measure 19: Deicing Materials ............................................................................................................ 28
Measure 20: Community Winter Access Trail Coordination............................................................... 28
Measure 21: Subsistence Access*........................................................................................................ 28
Measure 22: Continued Coordination with Local Tribe* .................................................................... 29
Measure 23: Air Quality Monitoring* ................................................................................................. 29
Measure 24: Use of Unmanned Aerial Vehicles* ................................................................................ 29
Measure 25: Polar Bear Maternal Den Detection Surveys * ............................................................... 30
Measure 26: Use of Surface Miner* .................................................................................................... 30
Measure 27: Protections for Teshekpuk Lake Area * .......................................................................... 30
4.0 Additional Mitigation Measures Considered but Not Adopted ..................................................... 31
4.1 Additional Suggested Avoidance, Minimization, or Mitigation Considered in the 2020 Willow
MDP Environmental Impact Statement .................................................................................. 33
4.2 Suggested Mitigation Measures from Public Comments on the 2022 Willow MDP Draft
Supplemental Environmental Impact Statement ..................................................................... 46
5.0 Other Required Mitigation Measures ............................................................................................ 51
5.1 Mitigation Measures in Support of Endangered Species Act Section 7 ................................. 51
5.1.1 Measures from Section 7 Consultation: U.S. Fish and Wildlife Service.......................... 51
5.1.2 Measures from Section 7 Consultation: National Marine Fisheries Service .................... 51
5.2 Mitigation Measures in Support of Magnuson-Stevens Fishery Conservation and Management
Act Essential Fish Habitat ....................................................................................................... 57
5.3 Beaufort Sea Incidental Take Regulations .............................................................................. 58
Appendix A Mitigation Measures Page i

5.3.1 Measures to Avoid and Minimize Potential Polar Bear Incidental Harassment .............. 58
5.3.2 Measures to Avoid and Minimize Potential Polar Bear Deterrence ................................. 59
5.4 NSB Rezoning Required Mitigation Measures ....................................................................... 59
6.0 Proponent’s Additional Mitigation Measures ............................................................................... 67
7.0 References ..................................................................................................................................... 68
List of Tables
Table 1.1 Lease Stipulations and Required Operating Procedures............................................................... 1
Table 1.2 Anticipated Exceptions from National Petroleum Reserve in Alaska Lease Stipulations and
Required Operating Procedures ................................................................................................... 2
Table 2.1 Design Features to Avoid and Minimize Impacts ........................................................................ 5
Table 4.1 Additional Suggested Avoidance, Minimization, or Mitigation from the 2020 Willow MDP
Environmental Impact Statement .............................................................................................. 33
Table 4.2 Cooperating Agency Suggested Mitigation Measures for the Willow MDP Supplemental
Environmental Impact Statement .............................................................................................. 37
Table 4.3. Public Comment Period Suggested Mitigation Measures ......................................................... 46
Table 5.1. Shutdown Zones for Each Activity ........................................................................................... 51
Table 5.2. North Slope Borough Rezoning Required Stipulations and Mitigation Measures .................... 60
Table 5.3. North Slope Borough Rezoning Conditions of Approval ......................................................... 64
Appendix A Mitigation Measures Page ii

List of Acronyms
AAQS Ambient Air Quality Standards
ADF&G Alaska Department of Fish and Game
ADEC Alaska Department of Environmental Conservation
AKDNR Alaska Department of Natural Resources
AOGCC Alaska Oil and Gas Conservation Commission
CPAI ConocoPhillips Alaska, Inc.
CWAT Community Winter Access Trail
DMLW Division of Mining, Land and Water
EFH Essential Fish Habitat
ESA Endangered Species Act
FAA Federal Aviation Administration
HDD horizontal directional drilling
IAP Integrated Activity Plan
ITRs Incidental Take Regulations
km kilometers
m meter
MMPA Marine Mammals Protection Act
MPH miles per hour
NEPA National Environmental Policy Act
NMFS National Marine Fisheries Service
NSB North Slope Borough
PM particulate matter
Proponent ConocoPhillips Alaska, Inc.
PSO Protected Species Observer
ROP required operating procedure
ROW right-of-way
UAV unmanned aerial vehicles
USFWS U.S. Fish and Wildlife Service
VSM vertical support member
WSE water surface elevation
Appendix A Mitigation Measures Page iii

Appendix A Mitigation Measures Page iv

1.0 APPLICABLE LEASE STIPULATIONS, REQUIRED

OPERATING PROCEDURES, AND DESIGN FEATURES
1.1 Lease Stipulations and Required Operating Procedures
The 2022 National Petroleum Reserve in Alaska (NPR-A) Integrated Activity Plan (IAP)/Environmental Impact
Statement (EIS) Record of Decision (ROD) established performance-based Lease Stipulations (LSs) and Required
Operating Procedures (ROPs) that apply to oil and gas activities within the NPR-A to avoid and minimize impacts
(BLM 2022a). In 2021, the Bureau of Land Management (BLM) was directed to reevaluate the 2020 NPR-A IAP.
The NPR-A IAP reevaluation resulted in the issuance of a new NPR-A IAP ROD (BLM 2022a) that selected an
alternative nearly identical to the 2013 NPR-A IAP ROD. Updated ROPs (BLM 2022a) adopted in the new NPR-
A IAP ROD replaced previous ROPs; however, LSs applicable to the Willow Master Development Plan (MDP)
Project (Project) have not changed because LSs are generally fixed at the time of the lease issuance. All projects
are subject to the ROPs that are in place at the time the permit for development is issued. (The reader is referred to
Section 2.2.7, Lease Stipulations, Required Operating Procedures, and Lease Notices, of the 2020 NPR-A
IAP/EIS for further discussion on this topic).
Table 1.1 lists the 2022 NPR-A IAP LSs and ROPs and denotes whether or not they are applicable to this project.
The reader is referred to the 2022 NPR-A IAP ROD [BLM 2022b] for the full text of all LSs and ROPs.
Table 1.1 Lease Stipulations and Required Operating Procedures
Applicability to the
Lease Stipulations (LSs) and Required Operating Procedures (ROPs)
Willow MDP Project
ROPs: A-1, A-2, A-3, A-4, A-5, A-6, A-7, A-8, A-9, A-10, A-11, A-12, B-1,
B-2, C-1, C-2, C-3, C-4, E-1, E-2, E-3, E-4, E-5, E-6, E-7, E-8, E-9, E-10, E-11, E-12, E-
Applicable 13, E-14, E-15, E-17, E-18, E-19, E-20, F-1, G-1, H-1, H-3, I-1, J, M-1, M-2, M-3, M-4
LSs: K-1, K-2, K-4, K-5, K-6, K-12
ROPs: C-5, D-1, H-2
LSs: K-3, K-8, K-9, K-10, K-11
ROP C-5 is not applicable because the Project does not include seismic activities.
ROP D-1 is not applicable because the Project does not include exploratory well activities.
ROP H-2 is not applicable because the Project does not include seismic activities.
Not Applicable LS K-3 is not applicable because the Project does not include exploratory well activities.
LS K-8 is not applicable because no Project activities would occur within the Brant Survey
Area.
LS K-9 is not applicable because no Project activities would occur within the Teshekpuk
Lake Caribou Habitat Area.
LS K-10 is not applicable because no Project activities would occur within the Teshekpuk
Lake Caribou Movement Corridor.
LS K-11 is not applicable because no Project activities would occur within the Southern
Caribou Calving Area.
Source: BLM 2022a
1.2 Exceptions to Lease Stipulations and Required Operating Procedures

Extensive work was conducted throughout the design and National Environmental Policy Act (NEPA) phases of
project development to avoid setbacks and minimize project footprint. However limited exceptions to certain LSs
and ROPs are necessary due to the technical requirements of the Project and physical constraints of the area that
would require essential proposed infrastructure to cross identified setbacks. The following exceptions (Table 1.2)
Appendix A Mitigation Measures Page 1

have been considered in the Final Supplemental EIS and are approved, as applicable, by this Decision and will be
incorporated into subsequent authorizations as relevant.
Table 1.2 Anticipated Exceptions from National Petroleum Reserve in Alaska Lease Stipulations and
Required Operating Procedures
LS or LS and ROP Description and Reason for Exception
ROPa
ROP A-5 Objective: Minimize the impact of contaminants from refueling operations on fish, wildlife, and the environment.
Requirement/Standard: Refueling of equipment within 500 feet of the active floodplain of any waterbody is
prohibited. Fuel storage stations shall be located at least 500 feet from any waterbody with the exception of small
caches (up to 210 gallons) for motorboats, float planes, ski planes, and small equipment (e.g., portable generators
and water pumps) are permitted. The authorized officer may allow storage and operations at areas closer than the
stated distances if properly designed to account for local hydrological conditions.
Reason for exception: Exceptions may be required to support refueling and fuel storage for marine vessels for
emergency response and refueling of specialized equipment for which regular movement is not feasible (e.g.,
drilling rigs, cranes) during construction activities within floodplains. (Specific waterbodies where exceptions may
be required have not yet been identified.)
ROP B-1 Objective: Maintain populations of, and adequate habitat for, fish and invertebrates.
Requirement/Standard: Withdrawal of unfrozen water from rivers and streams during winter is prohibited. The
removal of ice aggregate from grounded areas ≤ 4-feet deep may be authorized from rivers on a site-specific basis.
Reason for exception: Option 3 may require management of flowing water under the partially grounded ice bridge
over the Colville River at Ocean Point. This may result in the need to pump water around the ice bridge over 2
winters of ice bridge use.
ROP B-2 Objective: Maintain natural hydrologic regimes in soils surrounding lakes and ponds, and maintain populations of,
and adequate habitat for fish, invertebrates, and waterfowl.
Requirement/Standard: Withdrawal of unfrozen water from lakes and the removal of ice aggregate from grounded
areas ≤ 4-feet deep may be authorized on a site-specific basis depending on water volume and depth and the
waterbody’s fish community. Current water use requirements are:
a. Lakes with sensitive fish (i.e., any fish except ninespine stickleback or Alaska blackfish): unfrozen water
available for withdrawal is limited to 15% of calculated volume deeper than 7 feet; only ice aggregate may
be removed from lakes that are ≤ 7-feet deep.
b. Lakes with only non-sensitive fish (i.e., ninespine stickleback, Alaska blackfish): unfrozen water available
for withdrawal is limited to 30% of calculated volume deeper than 5 feet; only ice aggregate may be
removed from lakes that are ≤ 5-feet deep.
c. Lakes with no fish present, regardless of depth: water available for use is limited to 35% of total lake
volume.
d. In lakes where unfrozen water and ice aggregate are both removed, the total use shall not exceed the
respective 15%, 30%, or 35% volume calculations.
e. Additional modeling or monitoring may be required to assess water level and water quality conditions
before, during, and after water use from any fish-bearing lake or lake of special concern.
f. Any water intake structures in fish bearing or non-fish bearing waters shall be designed, operated, and
maintained to prevent fish entrapment, entrainment, or injury. Note: All water withdrawal equipment must
be equipped and must utilize fish screening devices approved by the Alaska Department of Fish and Game,
Division of Habitat.
g. Compaction of snow cover or snow removal from fish-bearing waterbodies shall be prohibited except at
approved ice road crossings, water pumping stations on lakes, or areas of grounded ice.
Reason for exception: Exceptions may be requested to allow for ice aggregate collection from bed-fast waterbodies
that exceeds regulatory withdrawal limits for liquid water and ice aggregate. Many of the lakes in the Project area
are shallower than the 7-foot and 5-foot maximum depth criteria and have documented sensitive or resident fish
species, resulting in little or no liquid water availability during winter. Removal of water as ice from areas with
grounded ice would not reduce the quantity of potential resistant overwintering fish habitat. Exception request
would not exceed the Alaska Department of Natural Resources water withdrawal criteria which ensure that
recharge will occur each spring. (Specific waterbodies where exceptions may be required have not yet been
identified.)


ROPa
ROP E-2 Objective: Protect fish-bearing waterbodies, water quality, and aquatic habitats.
Requirements/Standard: Permanent oil and gas facilities, including roads, airstrips, and pipelines, are prohibited
within 500 feet from the ordinary high-water mark of fish-bearing waterbodies. Essential pipeline and road
crossings will be permitted on a case-by-case basis.
Construction camps are prohibited on frozen lakes and river ice. Siting of construction camps on river sand and
gravel bars is allowed and encouraged. Where leveling of trailers or modules is required and the surface has a
vegetative mat, leveling shall be accomplished through blocking rather than use of a bulldozer.
Reason for exception: ROP E-2 requires a 500-foot setback from fish-bearing waterbodies, although essential
pipeline and road crossings are permitted on a case-by-case basis. Deviations from this ROP are warranted
because compliance is technically infeasible due to the hydrology and number of waterbodies in the Project area.
As a result, it is not possible in all instances to avoid encroachment within 500 feet of every waterbody. All action
alternatives include essential road and pipeline crossings of fish-bearing waterbodies and freshwater access
infrastructure.
ROP E-7 Objective: Minimize disruption of caribou movement and subsistence use.
Requirement/Standard: Pipelines and roads shall be designed to allow the free movement of caribou and the safe,
unimpeded passage of the public while participating in subsistence activities. Listed below are the accepted design
practices:
a. Above ground pipelines shall be elevated a minimum of 7 feet as measured from the ground to the
bottom of the pipeline at vertical support members.
b. In areas where facilities or terrain may funnel caribou movement, ramps over pipelines, buried
pipelines, or pipelines buried under roads may be required by the authorized officer after consultation
with federal, State, and North Slope Borough regulatory and resource agencies (as appropriate, based
on agency legal authority and jurisdictional responsibility).
c. A minimum distance of 500 feet between pipelines and roads shall be maintained. Separating roads
from pipelines may not be feasible within narrow land corridors between lakes and where pipelines
and roads converge on a drill pad. Where it is not feasible to separate pipelines and roads, alternative
pipeline routes, designs and possible burial within the road will be considered by the authorized
officer.
Reason for exception: While ROP E-7 requires a minimum distance of 500 feet between pipelines and roads, it is
acknowledged this may not be feasible in all areas. Initial pipeline engineering has identified that the minimum
distances would not be feasible in all areas for the Project based on road and pipeline design constraints.
Deviations would occur where roads and pipelines converge on a drill pad or at narrow land corridors between
lakes where it is not possible to maintain 500 feet of separation between pipelines and roads without increasing
potential impacts to waterbodies.


ROPa
ROP E-11 Objective: Minimize impacts on bird species, particularly those listed under the Endangered Species Act and BLM
Special Status Species, from direct or indirect interaction with infrastructure.
Requirement/Standard:
Bird species with special status are protected under ROP E-10 and ROP E-21, and by the protections outlined
below. In accordance with the guidance below, before the approval of infrastructure construction, the following
studies shall be conducted, and recommended design elements shall be incorporated.
Special Conditions in Spectacled and/or Steller’s Eiders Habitats:

a. The BLM will require submittal of a minimum of 3 years of site-relevant survey data before authorization
of construction, if such construction is within spectacled and Steller’s eider habitats, as defined by the area
contained within the USFWS Arctic Coastal Plain Aerial Waterbird Breeding Population Survey area or
the Barrow Triangle Steller’s Eider Survey area. The BLM will evaluate adequacy of survey data and
ecological mapping (as required under ROP E-12) to determine if ground- based nest surveys are required.
If required, spectacled and/or Steller’s eider ground nest surveys shall be conducted, following accepted
BLM protocol. Information gained from these surveys shall be used to make infrastructure siting decisions,
as discussed in subparagraph “b,” below. Data shall be transmitted to the BLM in a GIS format (ESRI
shapefiles referencing the North American Datum of 1983).
b. If spectacled and/or Steller’s eiders are determined to be present within the proposed development area, the
applicant shall work with the USFWS and BLM early in the design process to site roads and facilities in
order to minimize impacts to nesting and brood-rearing eiders and their habitats. Such consultation shall
address timing restrictions and other temporary mitigating measures, location of permanent facilities,
placement of fill, alteration of eider habitat, aircraft operations, and management of high noise levels.
Special Conditions in Yellow-billed Loon Habitats:

The permittee shall determine and submit to the BLM information on the presence of yellow-billed loon habitat
within a project area, using the most current data and analysis results from research conducted within the NPR-A.
a. If yellow-billed loon habitat is determined to be present within the project area, the BLM will require
submittal of a minimum of 3 years of site-relevant survey data of lakes greater than 25 acres within 1 mile
of the proposed infrastructure. If required, surveys along shorelines of lakes shall be conducted, following
accepted BLM protocol, during nesting in late June and during brood rearing in late August.
b. The design and location of infrastructure must be such that disturbance is minimized. The default standard
mitigation shall be a minimum 0.5-mile buffer around all recorded nest sites and shall be up to 1 mile,
where feasible. Lakes with yellow-billed loon occupancy shall also include a minimum 1,625-foot buffer
around the shoreline. Development would generally be prohibited within buffers. The BLM would consider
waivers or modifications to this requirement if no other feasible option exists.
Reason for exception: The Project will cross the default standard mitigation disturbance setback of 0.5 mile around
recorded nest sites for yellow-billed loons and a 500-meter (1,625-foot) setback of the shoreline of lakes with
yellow-billed loon occupancy.
LS K-1 Objective: Minimize the disruption of natural flow patterns and changes to water quality and the disruption of
natural functions resulting from the loss or change to vegetative and physical characteristics of floodplain and
riparian areas; the loss of spawning, rearing, or overwintering habitat for fish; the loss of cultural and
paleontological resources; the loss of raptor habitat; impacts on subsistence cabins and campsites; the disruption of
subsistence activities; and impacts on scenic and other resource values.
Requirement/Standard: Permanent oil and gas facilities (e.g., gravel pads, roads, airstrips, pipelines) are prohibited
in streambeds and adjacent to rivers listed. Rivers in the Project area that are listed include the Colville River (2-
mile setback), Fish (Creek (3-mile and 0.5-mile setback), Judy (Kayyaaq) Creek (0.5-mile setback), and the
Ublutuoch (Tiŋmiaqsiuġvik) River (0.5-mile setback).
Reason for exception: The Project will include essential road and pipeline crossings of Judy (Iqalliqpik) and Fish
creeks. Pipeline valve pads will also be located within the prescribed setbacks. The Project will locate the
Tiŋmiaqsiuġvik Gravel Mine Site within the prescribed setback.


ROPa
LS K-2 Deep Water Lakes
Objective: Minimize the disruption of natural flow patterns and changes to water quality; the disruption of natural
functions resulting from the loss or change to vegetative and physical characteristics of deepwater lakes; the loss
of spawning, rearing or overwintering habitat for fish; the loss of cultural and paleontological resources; impacts
on subsistence cabins and campsites; and the disruption of subsistence activities.
Requirement/Standard:
Generally, permanent oil and gas facilities, including gravel pads, roads, airstrips, and pipelines, are prohibited on
the lake or lakebed and within ¼ mile of the ordinary high water mark of any deep lake as determined to be in lake
zone III (i.e., depth greater than 13 feet [4 meters]; Mellor 1985). On a case-by-case basis in consultation with
federal, State and North Slope Borough regulatory and resource agencies (as appropriate based on agency legal
authority and jurisdictional responsibility), essential pipeline(s), road crossings, and other permanent facilities may
be considered through the permitting process in these areas where the lessee can demonstrate on a site-specific
basis that impacts will be minimal.
Reason for exception: The Project will include a water access pad near Lake M0015, a previously identified deep
water lake.
LS K-5 Coastal Area Setback
Objective: Protect coastal waters and their values as fish and wildlife habitat (including, but not limited to, that for
waterfowl, shorebirds, and marine mammals); minimize hindrance or alteration of caribou movement within
caribou coastal insect-relief areas; protect the summer and winter shoreline habitat for polar bears and the summer
shoreline habitat for walruses and seals; prevent loss of important bird habitat and alteration or disturbance of
shoreline marshes; and prevent impacts on subsistence resources and activities.
Requirement/Standard: b. Marine vessels used as part of a BLM-authorized activity shall maintain a 1-mile buffer
from the shore when transiting past an aggregation of seals (primarily spotted seals), Steller’s sea lions, or
walruses using a terrestrial haulout unless doing so would endanger human life or violate safe boating practices.
Marine vessels shall not conduct ballast transfers or discharge any matter into the marine environment within 3
miles of the coast except when necessary for the safe operation of the vessel.
Reason for exception: The Project will include sealift barge delivery of bulk construction materials, which will
require grounding of barges to facilitate offloading. Barge grounding will require ballast water transfers.
Note: ≤ (less than or equal to); BLM (Bureau of Land Management); LS (lease stipulation); ROP (required operating procedure).
a Excludes essential road and pipeline crossings.
2.0 APPLICABLE DESIGN FEATURES

ConocoPhillips Alaska, Inc. (the Proponent or CPAI), has incorporated measures into the Project design to avoid
and minimize impacts. These design features are listed in Table 2.1. Like LSs and ROPs, these design features are
also applicable to the Project and enforceable. Some of these design features are similar to NPR-A LSs and ROPs
or other requirements and are included to show the Proponent’s commitment to adhering to them. The Proponent
may propose additional measures in subsequent permitting phases.
Table 2.1 Design Features to Avoid and Minimize Impacts
No. Measure Project Component or LS, ROP, or Other Primary Affected
Activity Stipulationa Resource or Subject
1 Use directional drilling to reduce the overall Gravel infrastructure ROP E-5; AOGCC All
gravel footprint for drill site pads.
2 Construct road surfaces to the minimum width Gravel infrastructure ROP E-5; ADNR All
required for Project operations to minimize the DMLW
placement of gravel fill:
32-feet-wide Willow access and BT1 and BT2
roads
24-feet-wide water source access pads roads, airstrip
lighting roads, and BT3 infield road. Roads designed
with a smaller top (crown) surface avoid additional
fill placement where wider roads are not required.
3 Use 20-foot well spacing (instead of 30-foot Gravel infrastructure ROP E-5; AOGCC; Wetlands and
well spacing) to reduce the overall gravel ADNR DMLW vegetation
footprint for drill site pads.


4 Share use of existing equipment and facilities Gravel infrastructure ROP E-5; ADEC Water resources;
(e.g., camps, seawater treatment plant, wetlands and
warehouses, maintenance shops, emergency vegetation
response equipment) to reduce the overall
Project gravel- and ice-pad footprint.
5 Use single-season ice roads to support winter Gravel infrastructure, ROP E-5; ADNR Wetlands and
construction of gravel roads, pads, and pipelines mine site DMLW vegetation
to avoid the need for additional gravel roads for
construction. This includes accessing
Tiŋmiaqsiuġvik mine sites via ice road instead
of gravel.
6 Use 2:1 side slopes (i.e., gravel road and pad Gravel infrastructure ROP E-5 Wetlands and
embankment slopes) instead of 3:1 to reduce the vegetation
Project’s overall gravel footprint.
7 Locate drill site BT4 (and associated roads and Gravel infrastructure, Design Measure Wetlands and
pipelines under Alternatives B, C, and D) pipelines does not apply to vegetation; terrestrial
outside of the Teshekpuk Lake Caribou Habitat Project as approved mammals
area which would reduce the overall gravel under this Decision
footprint and eliminate the need for a bridged as BT4 would not
crossing of the Kalikpik River. be constructed.
8 Avoid permanently flooded wetlands by Gravel infrastructure None Wetlands and
locating Project infrastructure on higher, and vegetation; water
relatively drier areas, when practicable. This resources
practice applies to drill sites and other pads,
road alignments, the new airstrip, and other
Project components.
9 Suspend communications and power cables Utilities ROP E-20 Wetlands and
from horizontal support members to avoid vegetation; birds
additional fill associated with utility poles and
to reduce the potential for bird strikes and
perches for predators.
10 Use ice roads and pads, including multi-season Construction activity ROP E-5; ADEC; All
ice pads, to support Project construction, ADNR DMLW
including using ice pads to house construction
camps; stage construction equipment; allow
stockpiling of gravel and mine site overburden
during construction activities; and support
construction activities at bridge crossings, along
the Project’s pipeline alignment, at the HDD
crossing of the Colville River, and at other
locations as needed near the proposed
infrastructure.
11 Design pipelines to minimize redundant parallel Pipelines ROP E-7; AOGCC; Wetlands and
pipelines to the extent practicable. ADEC vegetation; birds;
(For example, infield pipelines from drill site terrestrial mammals;
BT2 would tie into drill site BT1 pipelines at spill risk
BT1; and then drill site BT1 infield pipelines
would connect with the WPF. Additionally, the
Willow export pipeline would tie into the
existing Alpine Sales oil pipeline at a tie-in pad
near Alpine CD4N to connect the Project to the
Trans-Alaskan Pipeline System.)
12 Co-locate the WPF with drill site BT3 to Gravel infrastructure ROP E-5; AOGCC Wetlands and
eliminate the need for an additional gravel pad vegetation
and associated gravel fill (Alternative D only).


13 Construct oil and gas facilities and other Project Gravel infrastructure, ROP E-2; ADF&G; Water resources; fish
infrastructure more than 500 feet from fish- pipelines ADEC; ADNR
bearing waterbodies, to the maximum extent DMLW
practicable. Only essential pipeline road
crossings are proposed for the Project that
would encroach on this minimum distance.
(For example, the intersection between the BT1
and BT3 access roads was realigned and shifted
west to locate the BT1 road outside of the 500-
foot buffer of swale 2, an anadromous
waterbody.) Construction camps would not be
sited on frozen lakes or rivers. (Anticipated
deviations are noted in the EIS.)
14 Consult with appropriate federal, state, and Gravel source ROP E-8; ADF&G; Soils, permafrost, and
NSB agencies regarding the mine site design ADEC; NSB; gravel resources; visual
and reclamation plan. Design mine site to ADNR DMLW resources; water
minimize impacts to wildlife, air quality, and resources; wetlands
water resources. Mine site operation and and vegetation; fish;
reclamation would include the storage and reuse birds; subsistence and
of organic overburden (for the mine sites). Site sociocultural systems
the mine pits outside of the active floodplain to
minimize impacts to water resources.
15 Design, construct, maintain, and operate roads Gravel infrastructure ROP E-1; ADEC; Soils, permafrost, and
in ways to minimize environmental impacts and ADNR DMLW gravel resources; water
protect subsistence use areas and access. Gravel resources; subsistence
road alignments and pad layouts would consider and sociocultural
topography, maintenance of natural drainage systems
patterns, and the effects of spring breakup and
other potential flood events. Road and pad
layouts would also avoid ponds, lakes, and
streams to the extent practicable.
16 Restrict summer tundra vehicle travel for Personnel ROP L-1; ADF&G; Soils, permafrost, and
Project personnel to emergency response or to ADNR DMLW gravel resources; water
permitted activities required by statute or resources; wetlands
regulation. and vegetation; fish;
birds; terrestrial
mammals; marine
mammals
17 Conduct overland (i.e., tundra) moves and Off-road vehicle use ROP C-2; ADF&G; Soils, permafrost, and
similar off-road or cross-country activity use in ADNR DMLW gravel resources; water
accordance with ROP C-2 to minimize impacts resources; wetlands
to streambanks, soil substrate, and vegetation. and vegetation; fish;
birds; terrestrial
mammals; marine
mammals
18 Use low-angle approaches for ice road Ice infrastructure ROP C-3; ADF&G; Soils, permafrost, and
waterway crossings to protect streambanks. ADEC; ADNR gravel resources; water
Waterway crossings reinforced with additional DMLW resources; fish;
snow or ice (“bridges”) would be removed, terrestrial mammals;
breached, or slotted prior to spring breakup to marine mammals
maintain normal spring runoff patterns and fish
passage. All constructed ice ramps and ice
bridges would be substantially free of debris
(e.g., sticks, brush).


19 Prohibit travel along streambeds unless it can be Ice infrastructure ROP C-4; ADF&G; Water resources; fish
demonstrated that there would be no additional ADEC; ADNR
impacts from such travel to over-wintering fish DMLW
or the invertebrates they rely on. Rivers,
streams, and lakes would only be crossed with
ice infrastructure at areas where waterbody or
waterway ice has grounded, when practicable.
20 Inject produced water into the reservoir and do Waste management ROPs A-2 and A-7; Water resources;
not discharge it to surface lands, surface waters, ADF&G; ADEC wetlands and
or marine waters. vegetation; fish; birds;
terrestrial mammals;
marine mammals;
subsistence and
sociocultural systems;
public health
21 Use recent ecological mapping to assess Gravel infrastructure ROP E-12; ADF&G Wetlands and
wildlife habitat types to inform the design, vegetation; fish; birds;
placement, and development of permanent terrestrial mammals;
(i.e., gravel) infrastructure. marine mammals
22 Remove, slot, breach, or score ice road stream Ice infrastructure ROP C-3; ADF&G; Soils, permafrost, and
crossings prior to spring breakup to ensure ADNR DMLW gravel resources; water
adequate flow and drainage conditions at stream resources; wetlands
crossings. and vegetation; fish;
birds
23 Place gravel roads perpendicular to the general Gravel infrastructure ROP E-6; ADNR Water resources;
flow direction when crossing natural drainages DMLW; ADF&G wetlands and
to maintain the existing flow patterns and vegetation; fish; birds
characteristics.
24 Design and construct stream and swale Gravel infrastructure ROP E-6; ADF&G; Water resources;
crossings to ensure the free passage of fish, ADNR DMLW wetlands and
minimization of erosion, maintenance of natural vegetation; fish; birds
drainage characteristics, and the minimization
of impacts to natural stream flow. Bridges
would be used to cross rivers and major
streams.
25 Collect 3 years of hydrologic and fish data at Gravel infrastructure ROP E-14; Fish
stream crossing and ensure fish passage at ADF&G; ADEC
stream crossings.
26 Design fish-passage culverts in consultation Gravel infrastructure ADF&G; ADEC Fish
with ADF&G.
27 Install cross-drainage culverts as needed to Construction ROP E-6; ADF&G Soils, permafrost, and
maintain natural surface drainage to mitigate the gravel resources; water
risk of sheet flow interruption and resources; wetlands
thermokarsting. The estimated spacing of and vegetation; birds
culverts is approximately every 1,000 feet.
(Exact placement would be adjusted based on a
field survey of in-field local drainage patterns.)
28 Place bridges and river crossings at narrow river Gravel infrastructure ADF&G Water resources;
sections, where practicable, to avoid gravel fill wetlands and
and minimize the number of piers/pilings placed vegetation; fish
below ordinary high water.
29 Construct bridge abutments from sheet pile to Construction ROP E-6; ADF&G; Soils, permafrost, and
reduce the overall gravel footprint and protect ADEC gravel resources; water
the structures from embankment erosion and resources; fish
stream scour.


30 Do not stockpile gravel in Waters of the U.S., Gravel infrastructure ADF&G; ADNR Soils, permafrost, and
including wetlands. Gravel would be stockpiled DMLW gravel resources; water
in upland areas or on ice pads. resources; wetlands
and vegetation; birds
31 Install vertical support members (for pipelines) Construction AOGCC; ADNR Soils, permafrost, and
from ice roads and pads, and ensure drill DMLW gravel resources; water
cuttings are temporarily stored on ice and resources; wetlands
removed to the gravel mine site prior to spring and vegetation
breakup.
32 Conduct trenching activity (e.g., pipeline road Construction ADNR DMLW Soils, permafrost, and
crossings) during winter and temporarily store gravel resources; water
trench materials on plywood, plastic sheeting, or resources; wetlands
an ice pad to avoid additional impacts to and vegetation
wetlands (e.g., fill).
33 Minimize heat transfer and impacts to Construction and ADEC; ADNR Soils, permafrost, and
permafrost from Project infrastructure on gravel operations gravel resources
pads by: designing flare stack height to reduce
radiant heating; filling the gap between well
conductors and inner pipes with polyurethane
foam; using thermosyphons adjacent to well
rows and at-grade structures; and installing
insulation below the foundation floors of
heated, at-grade structures.
34 Elevate on-pad heated buildings or structures Facilities ADEC Soils, permafrost, and
using pilings, to the extent practicable, to gravel resources
prevent or reduce heat transfer to underlying
soils and preserve the thermal integrity of the
permafrost.
35 Implement snow removal management Construction and ADNR DMLW Soils, permafrost, and
measures to reduce the potential for gravel to be operations gravel resources; water
pushed off roads and pads during snow removal resources; wetlands
operations. and vegetation
36 Implement dust control measures for gravel Gravel infrastructure ROP A-10; ADEC Soils, permafrost, and
roads, pads, and mining operations to reduce gravel resources; air
fugitive dust that can settle on vegetation or quality; visual
snow, which could increase thermal resources; water
conductivity (i.e., reduce albedo), lead to resources; wetlands
thermokarsting, and promote earlier spring thaw and vegetation; fish;
in affected areas. birds; terrestrial
mammals; public
health
37 Implement strict guidelines for travel on ice Ice road travel ADF&G; ADNR Soils, permafrost, and
roads to avoid tundra damage, including DMLW gravel resources;
requiring ice road driver training, establishing wetlands and
speed and weight limits, and installing road- vegetation; birds;
edge delineators along both sides of roads. terrestrial mammals
38 Install Colville River pipeline crossings Pipelines ADEC Soils, permafrost, and
(e.g., diesel, seawater) with insulation and gravel resources;
placed within an outer pipeline casing, which Water resources; Spill
would inhibit heat transfer to permafrost, risk
contain fluids in the event of a pipeline leak,
and provide structural integrity to the pipeline
crossing.

No. Measure Project Component or LS, ROP, or Other

Primary Affected
39 Design, construct, and use ice roads that are a Ice infrastructure ROP C-2; ADF&G; Soils, permafrost, and
minimum of 6 inches thick during winter ADNR DMLW gravel resources;
construction to eliminate or minimize impacts wetlands and
to wetlands and tundra. vegetation; birds;
terrestrial mammals
40 Implement an erosion control plan to detail Erosion control ROP E-6; ADF&G; Soils, permafrost, and
ways the Project would prevent or mitigate ADEC; ADNR gravel resources; visual
erosion that could impact terrestrial and aquatic DMLW resources; water
environments. The plan would include CPAI’s resources; wetlands
operations, monitoring, and maintenance and vegetation; fish;
procedures that detail the actions CPAI would birds; terrestrial
undertake to monitor, maintain, and if needed, mammals; marine
remediate gravel fill impacting surrounding mammals; subsistence
tundra and wetlands. and sociocultural
systems
41 Place cleared (i.e., plowed) snow in designated Snow management ROP A-3; ADNR; Soils, permafrost, and
snow-storage areas and manage stormwater ADEC gravel resources; water
from all gravel pads to prevent contaminants resources; wetlands
from being released during spring breakup. and vegetation
Select snow push areas annually based on
avoiding areas of thermokarsting, proximity to
waterbodies, and evaluations of areas used the
previous year.
42 Use a minimum of 5-foot-thick section for Gravel infrastructure ROP E-5; ADNR Soils, permafrost, and
gravel pads and roads to maintain a stable DMLW gravel resources
thermal regime by insulating the underlying
tundra and offsetting the loss of insulating effect
caused by the compression of the vegetated
tundra beneath the gravel.
43 Route ice roads to avoid shrub areas and large Ice infrastructure ROP C-2; ADF&G; Wetlands and
areas of tussock tundra to the extent practicable. ADNR DMLW vegetation; birds;
terrestrial mammals
44 Construct pipelines aboveground, to the extent Pipelines ADEC; ADNR Soils, permafrost, and
practicable, to minimize permafrost impacts. gravel resources
45 On BLM-managed lands, withdraw unfrozen Water withdrawal ROP B-1; ADNR Water resources; fish
water from lakes and not rivers and streams DMLW; ADEC
during winter to maintain populations of, and
adequate habitat for, fish and invertebrates. Ice
aggregate would not be removed from areas of
grounded ice less than or equal to 4 feet in depth
(on BLM-managed lands) without authorization
from the BLM, on a site-specific basis.
46 Do not construct causeways or docks in any Gravel infrastructure ROP E-3; ADNR Water resources; fish;
river mouth or delta. Causeways, docks, DMLW; ADF&G birds
artificial islands, or other bottom-fast structures,
if employed, would be designed to ensure free
passage of fish and prevent changes to water
circulation patterns or water quality.


47 Maintain air-traffic altitudes consistent with Air traffic ROP F-1; ADF&G Noise; visual
NPR-A ROP F-1, except during takeoffs and resources; birds;
landings, and unless doing so would endanger terrestrial mammals;
human life or violate safe flying practices, to marine mammals;
avoid disturbing caribou, birds, and subsistence subsistence and
users, when feasible. (Some air traffic would be sociocultural systems
required to support the Project or for regulatory
compliance [e.g., wildlife studies, hydrology
studies] and to ensure cleanup following the ice-
road season could require flying at lower
altitudes.)
48 Develop a bear-interaction plan for Project All ROP A-8; ADF&G Terrestrial mammals;
personnel to minimize conflicts between bears marine mammals
and humans.
49 Minimize disruption to caribou movement by Pipelines ROP E-7; ADF&G; Terrestrial mammals;
maintaining a minimum clearance of 7 feet ADEC subsistence and
between the bottom of pipelines and the ground sociocultural systems;
surface. spill risk
50 Design facilities to minimize nesting, denning, Facilities ROP E-9; ADF&G Birds; terrestrial
or sheltering opportunities for ravens, raptors, mammals
and foxes. Prohibit intentional feeding of
wildlife.
51 Minimize the amount of light visible from Facility lighting ROP E-10; typical Birds
outside of facilities, including directing artificial ESA conservation
exterior lighting inward and downward during measure; ADF&G
all months of the year, which would prevent
waterfowl (including species listed under the
ESA) from striking facilities during low light
conditions.
52 Minimize the take of species, particularly those Facilities ROPs E-11 and J; Birds
listed under the ESA and BLM Special Status typical ESA
Species, by conducting eider and yellow-billed conservation
loon surveys and working with resource measure; ADF&G
agencies to ensure facilities minimize impacts to
species found (e.g., ensure off-pad utility lines
are either buried or suspended from pipe racks
to the extent feasible, locate towers on pads near
existing buildings to the extent feasible,
minimize the use of tower guy wires, clearly
mark guy wires that are used to prevent
collisions).
53 Develop a new gravel mine site that would not Gravel source ROPs E-8 and E-15; Birds
result in the loss of raptor nesting habitat ADF&G
because it would not take gravel from cliffs,
river channels, or stream channels in a manner
that would affect river bluffs.
54 Minimize the electrocution hazard by Utilities ROP E-20; typical Birds
suspending electrical distribution lines from ESA conservation
pipe racks or burying cables (versus the use of measure; ADF&G
overhead power lines) off pad.
55 Provide the BLM authorized officer with GIS- Facilities ROP E-19; ADF&G Birds; terrestrial
compatible location information to facilitate mammals
agency monitoring and assessment of wildlife
movements through the Project area after
Project construction.


56 Locate pipelines parallel to new and existing Pipelines ROP E-7; ADF&G Terrestrial mammals;
gravel roads and maintain a minimum spill risk
separation distance of 500 feet, where feasible,
to minimize caribou disturbance and prevent
excessive snow accumulation from snowdrifts
and snow removal.
57 Contract with a state-registered Primary Operations ROP A-4; ADEC Spill risk
Response Action Contractor to assist with quick
spill response impacts in the event of a spill.
58 Align pipe racks installed adjacent and parallel Pipelines ADNR Birds; terrestrial
to existing pipeline racks so vertical support mammals; subsistence
members for each pipe rack are in line, to the and sociocultural
extent practicable, to reduce obstructions to systems
caribou and subsistence user movements.
59 Use a muted (i.e., non-reflective) coating on Pipelines ADNR Visual resources; birds;
pipelines to avoid glare. terrestrial mammals;
marine mammals;
subsistence and
sociocultural systems
60 Implement policies, procedures, and training to Waste management and ROPs A-8 and I-1; Birds; terrestrial
prevent wildlife attraction to Project facilities, wildlife interaction ADEC mammals; marine
including use of predator-proof dumpsters for mammals
food waste collection; a strict policy prohibiting
the feeding of wildlife; and the use of Ziploc
bags or other sealed containers for meals-on-
the-go to conceal food odors.
61 Implement a Wildlife Avoidance and Waste management ROPs A-1, A-2, A- Birds; terrestrial
Interaction Plan that would include procedures 8, and I-1; typical mammals; marine
to eliminate, minimize, and mitigate bear ESA conservation mammals
interactions. CPAI conducts training on waste measure; ADF&G;
management practices and would conduct ADNR; ADEC
Project-specific training on waste management
to guide employees and contractors on
managing predators.
62 Protect grizzly and polar bear denning sites by All ROP C-1; typical Terrestrial mammals;
prohibiting cross-country travel or use of heavy ESA conservation marine mammals
equipment within 0.5 mile of a grizzly bear den measure; ADF&G;
and within 1.0 mile of a polar bear den. Where ADNR DMLW
necessary, CPAI would conduct surveys near
coastal areas to locate potential polar bear dens,
in consultation with the U.S. Fish and Wildlife
Service, as appropriate, before initiating
activities in coastal habitat between October 30
and April 15.
63 Conduct training for Project personnel on NPR- Personnel ROP I-1; NSB Subsistence and
A ROPs, standards, and environmental, social, sociocultural systems;
traditional, and cultural concerns specific to the cultural resources
Project region, including training on community
interactions. This training would be designed to
ensure strict compliance with local and
corporate drug and alcohol policies.
64 Prohibit Project employees from hunting and Personnel ROP H-3; ADF&G Subsistence and
trapping activities while employees are on sociocultural systems
active work status to avoid increased
competition for subsistence and recreational
wildlife resources.


65 Use the results of cultural and paleontological Construction ROP E-13; ADNR Cultural and
resource surveys to inform Project design and paleontological
facilities placement. The Project would avoid resources
known cultural and paleontological resources
during ground-disturbing activities, including
the construction of ice roads.
66 Implement a Visual Resources Management Project infrastructure ROP E-17; ADNR Visual resources
Plan to minimize visual resource impacts,
consistent with the Visual Resources
Management Class for the lands on which
Project facilities would be located.
67 Avoid disturbance of caribou and strictly Personnel ROP M-1; ADF&G Birds; terrestrial
prohibit chasing wildlife with vehicles. mammals; marine
mammals; subsistence
and sociocultural
systems
68 Continue to consult with affected subsistence All ROP H-1; NSB Subsistence and
communities, tribes, Alaska Native sociocultural systems
Corporations, and NSB, as well as the
Kuukpikmuit Subsistence Oversight Panel,
Alaska Eskimo Whaling Commission, Nuiqsut
Whaling Captains, and Barrow Whaling
Captains to mitigate potential impacts to
subsistence activities. Plans would be
maintained to ensure these consultations
continue both periodically and robustly.
69 Continue to consult with the Kuukpik All ROPs E-1, F-1, H-1, Subsistence and
Subsistence Oversight Panel, the Native Village H-3, and I-1; NSB sociocultural systems
of Nuiqsut, and Kuukpik Corporation to ensure
Project activities do not adversely affect
subsistence activities. CPAI would continue to
hold frequent public community meetings well
in advance of future activities. Travel would be
scheduled with flexibility and managed through
the use of speed limits, rerouting, and traffic
stoppages to avoid conflict with subsistence use
and hunting areas during seasonal periods.
70 Continue to provide annual funding for the All ROPs E-1, F-1, H-1, Subsistence and
Kuukpik Subsistence Oversight Panel to help H-3, and I-1; NSB sociocultural systems
support the executive director and coordinate
panel activities.
71 Conduct high-disturbance construction activities Construction ADF&G Water resources; fish;
such as gravel mining and placement, and birds; terrestrial
pipeline and facility construction, primarily mammals; subsistence
during the winter months when subsistence and sociocultural
activity levels are relatively low and disruptions systems
to water flows can be minimized.
72 Include subsistence tundra access ramps and Gravel infrastructure ADNR DMLW; Subsistence and
pullouts on gravel roads with locations based on NSB sociocultural systems
community input. The pullouts would allow
local residents to access the areas adjacent to
roadways. The tundra access ramp and pullouts
would be designed with considerations of
lessons learned from the Greater Mooses Tooth
1 and 2 projects.


73 Prohibit the use of airboats on rivers within Operations ADNR DMLW; Noise; birds; fish;
BLM-managed lands and within a 50-mile ADF&G terrestrial mammals;
radius of Nuiqsut, except for emergencies and marine mammals;
emergency response training. subsistence and
sociocultural systems
74 Continue the internship program (CareerQuest) Community outreach NSB Economics;
to introduce Nuiqsut high school students to subsistence and
jobs and careers in the oil fields and in their sociocultural systems
community.
75 Continue to strive to hire qualified Nuiqsut, Personnel NSB Economics
NSB, and Alaska residents for oil field jobs.
76 Ensure current communications protocols for Air and vessel traffic ROP F-1; NSB Subsistence and
CPAI helicopter, fixed-wing aircraft, and sociocultural systems
marine-vessel traffic are adequate to address
community (Nuiqsut) concerns about traffic-
related impacts to subsistence activities.
77 Allow Nuiqsut residents reasonable use of Gravel infrastructure ROPs E-1 and H-1; Subsistence and
Project roads to access subsistence areas NSB; ADNR sociocultural systems
throughout the life of the Project. DMLW
78 Implement avoidance measures to ensure All NSB Cultural resources
protection of cultural resource sites during
Project activity by establishing a 500-foot
avoidance buffer consistent with NSB
regulations.
79 Reduce and minimize air pollution through air Air emissions ROP A-10; ADEC; Air quality; public
quality monitoring and modeling, as NSB health
appropriate. Develop an emissions inventory
and apply additional mitigation measures and
activity modifications, as appropriate, in
response to the air quality information
generated. Make reports generally available to
the NSB and local communities.
80 Adhere to the BLM’s oil and gas air resources All ADEC Air quality; climate
ROPs, as applicable. These practices would change; water
minimize air emissions resulting from both resources; wetlands
Project construction and operations and would and vegetation; public
include: watering gravel roads to minimize health
fugitive dust, using clean fuels such as ultra-low
sulfur diesel and natural gas, and the use of low
emissions emitting equipment (including
maximum use of electrical power, Tier IV final
engines - or similar emission reduction
technology for drill rigs and hydraulic fracturing
equipment prior to WPF facility startup –
storage tank closed vent systems to the extent
practicable, and green completions).
81 Use ultra-low sulfur diesel fuel (as defined by Vehicles and equipment ROP A-9; ADEC Air quality; public
ADEC) in all diesel-fueled vehicles and health
equipment.
82 Use totally enclosed or acoustically packaged Generators ADEC Noise; birds; terrestrial
permanent electric power generator sets to abate mammals; marine
noise. mammals


83 Generate Project power using the power plant at Utilities
ADEC; AOGCC Air quality; public
the WPF following facility startup and provide health
power to drill rigs except during periods when
power from the WPF is unavailable. Use ultra-
low-sulfur diesel powered portable generators to
supply Project power prior to facility startup or
during periods of facility maintenance,
shutdown, or upsets.
84 Power off vehicles and heavy equipment Vehicles ROP A-7; ADEC Air quality; climate
(i.e., rolling stock) used for oil and gas change; public health
operations when not in active use, to the extent
practicable.
85 Equip vehicles with block heaters and institute Vehicles ADEC Air quality; climate
Project practices to power off and plug in change; public health
vehicle engines when temperatures are -30°F or
above to conserve fuel and reduce emissions.
86 Use Finewater Mist for process module fire Fire protection ADEC Air quality; water
protection and a non-ozone depleting agent for quality
drill site and non-process module fire protection
in lieu of Halon.
87 Manage all waste in accordance with a Waste management ROP A-2; ADEC Water resources;
comprehensive waste management plan to wetlands and
reduce impacts to human health and safety and vegetation; birds;
to minimize potential effects to subsistence terrestrial mammals;
resources, including fish and wildlife. This marine mammals;
would be accomplished using the Alaska Waste subsistence and
Disposal and Reuse Guide (the “Red Book”). sociocultural systems
This guide addresses: waste prevention and
reduction, recycling, treatment, and disposal.
The waste management plan would include
measures to avoid attracting wildlife, disposal
of putrescible waste, disposal of pumpable
waste, and disposal of wastewater. As allowed,
injectable waste would be injected into the
subsurface via disposal wells or used for
enhanced oil recovery.
88 Audit contractors’ health, safety, and Personnel ADEC Water resources
environment performance to ensure safe wetlands and
practices are followed. vegetation; fish; birds;
terrestrial mammals;
marine mammals;
subsistence; public
health
89 Audit the Project on a scheduled basis to ensure All ADNR DMLW; All
compliance with all environmental laws, ADEC
regulations, and local requirements, company
policies and procedures, and other regulations
regarding safety, land use, fire codes, etc.
90 Employ Field Environmental Coordinators to All ADNR All
monitor compliance with permits and other
Project requirements.
91 Evaluate environmental considerations when All ROP A-10; ADEC All
purchasing new storage tanks or adding new
emissions sources that may affect the
environment or operating permits.


92 Review new chemicals being considered for use Operations ROP A-3; ADEC All
on the Project to ensure the materials would
minimize the generation of hazardous waste or
risk to employees.
93 Develop and implement a spill prevention and Spill prevention and ROP A-4; ADEC All
response contingency plan for the Project (in response
accordance with 40 CFR 112) to reduce impacts
to human health and safety and to minimize
potential effects to subsistence resources,
including fish and wildlife. The Plan would
cover Project operations and describe spill
prevention measures and on-site cleanup
materials for permanent fueling stations, use of
proper storage containers and liner materials,
proper container identification, and notice of
reportable spills. Identification of drip pans
(i.e., “duck ponds”) would be addressed through
Project operating procedures.
94 Use a hazardous materials contingency plan Spill prevention and ROP A-3; ADEC All
(also known as a spill prevention and response response
contingency plan), prepared pursuant to NPR-A
ROP A-3, that would detail response actions,
drills, and responder training.
95 Build and operate pipelines with the best Pipelines ROP E-4; ADEC All
available technology for detecting and
preventing corrosion or mechanical defects to
minimize impacts related to point source
pollution from oil spills or leaks.
96 Install pipeline valves on each side of Judy Pipelines ADEC All
(Kayyaaq) and Fish creek crossings, to allow
isolation of produced fluids pipelines on either
side of bridges and minimize potential spill
impacts in the event of a leak or break. These
valves would reduce subsistence user concerns
related to downstream contamination from the
Project. Isolation valves or vertical loops would
be installed on the Willow (sales oil) pipeline at
each side of the Ublutuoch (Tiŋmiaqsiuġvik)
River, and on each side of the segment crossing
the Nigliagvik Channel, Niġliq Channel, and
lakes L9341 and L9323. Vertical loops would
be installed on the diesel pipeline at each side of
the Miluveach River, Kachemach River, and
Colville River. Two methods of leak detection
will be used for the seawater and diesel pipeline
crossings under the Colville River: (1) leak
detection mass balance (primary), and (2)
optical leak detection (secondary, within
casing).
97 Implement CPAI’s “Target Zero” spill Spill prevention and ROP A-3, A-4, and All
prevention program, which is designed to raise response A-5; ADEC
awareness around spill prevention and pass on
lessons learned, for the Project.


98 Implement a fuel transfer standard operating Spill prevention and ROPs A-4 and A-5; All
procedure and use secondary containment on response ADEC
regulated oil and hazardous materials storage
tanks.
99 Continue to implement an extensive corrosion Spill prevention and ROP A-3; ADEC All
inspection program which includes ultrasonic response
inspection, radiographic inspection, coupon
monitoring, metal loss detection pigs and
geometry pigs (applicable to pig-capable
pipelines), and infrared (heat signature
detection) technology. The inspection programs
are American Petroleum Institute Standard 570-
based programs that focus inspection efforts on
areas of greatest potential for spills.
100 Continue CPAI’s operating practice to Spill prevention and ROP A-3; ADEC All
immediately and completely clean up all spills, response
recovering 100% of spilled material for
recycling when possible.
101 Periodically treat pipeline fluids, as appropriate Pipelines ROPs A-3 and E-4; All
to product types, with chemicals to limit ADEC
corrosion potential.
102 Equip and maintain oil spill response equipment Spill prevention and ROPs A-3 and A-4; All
intended for use in winter conditions for response ADEC
effective use in Arctic conditions (i.e., in a
manner to prevent the freezing or icing of the
equipment).
103 Hydrostatically test pipelines prior to placing Pipelines ROP E-4; ADEC All
them into operation.
104 Provide access to the GMT and Alpine Spill prevention and ROPs A-3 and A-4 All
developments (under Alternatives B, C, and E) response
to offer additional response capabilities and
minimize response time in the event of a spill or
other unintended release or emergency.
105 Stage spill response equipment in strategic Spill prevention and ROPs A-3 and A-4; All
locations (e.g., drill sites) for initial spill response ADEC
response. On-site staged equipment would
facilitate the rapid deployment of response
personnel and may minimize or reduce the
overall impacts associated with a spill or other
accidental release.
106 Designate Spill Response Teams and Hazardous Spill prevention and ROP A-3; ADEC All
Materials Response Teams, consisting of response
trained volunteer spill and hazardous materials
response personnel on site.
107 Continue to participate in the Mutual Aid Spill prevention and ROP A-3; ADEC; All
Agreement among North Slope operators to response NSB
supply labor and equipment for immediate spill
response. Spill response drills and exercises
would ensure response readiness and
awareness; these drills would be scheduled
according to the National Preparedness and
Response Exercise Program guidelines and
typically involves production, drilling, or
pipeline spill response scenarios


108 Do not refuel equipment within 500 feet of the Spill prevention and ROP A-5; ADNR All
active floodplain of any waterbody unless response DMLW; ADEC
approved by the BLM authorized officer. Fuel-
storage stations, except as approved by the
BLM authorized officer, would be located at
least 500 feet from waterbodies except for small
caches (up to 210 gallons) for fueling
motorboats, float planes, and small equipment.
109 Design well cellars to contain fluid drips and Spill prevention and ROP A-4; ADEC All
leaks. response
110 Continue philanthropy programs from local oil All None Economics;
fields to provide income and other benefits to sociocultural systems;
the residents of Nuiqsut. public health
111 Design all bridges to maintain bottom chord Bridges ROP E-6 Soils, permafrost, and
clearance of at least 4 feet above the 100-year gravel resources; water
design flood elevation, or at least 3 feet above resources; wetlands
the highest documented flood elevation, and vegetation; fish;
whichever is higher. Additionally, design the birds; terrestrial
Judy (Kayyaaq) Creek and Fish Creek bridges mammals; marine
to maintain bottom chord clearance of at least mammals; subsistence
13 feet above the 2-year design flood elevation and sociocultural
(open water) to provide vessel clearance. systems; public health
112 Include construction of up to three subsistence All ROP E-1 Subsistence and
boat ramps to provide local residents with sociocultural systems;
improved river access. Locations would include public health
the Ublutuoch (Tiŋmiaqsiuġvik) River near the
existing GMT-1 access road, Judy (Kayyaaq)
Creek at the proposed Willow BT1 access road
crossing, and Fish Creek at the proposed access
road crossing (BT2 under Alternative E).
113 Implement a speed limit of 35 mph and stop Gravel infrastructure None All
traffic when caribou are crossing the road on all
32-foot-wide (surface width) roads. On roads
with a 24-foot-wide surface width, implement a
25-mph speed limit for health, safety, and
environmental purposes, including to reduce
potential impacts to vegetation from dust and to
wildlife.
114 Build a constructed freshwater reservoir to Water withdrawal None Water resources;
ensure a reliable source of fresh water for the wetlands and
Project while minimizing the need for water vegetation; fish; birds
withdrawals from Willow-area lakes.
Adaptively manage water levels by installing a
flow control gate and valve to allow reduction
of flow velocity into the reservoir based on
monitoring of water levels in Lake M0015 and
the lake outlet into Willow Creek if necessary.
115 Place pipelines at Fish Creek and Judy Pipelines LS K-1 Water resources; fish;
(Kayyaaq) Creek on structural steel supports birds
attached to the bridge girders below the bridge
deck to avoid placement of pipeline VSMs
below OHW.
116 Remove the airstrip approach lighting access Gravel infrastructure ROP E-5 All
and secondary access roads from the proposed
Project design to reduce the gravel footprint.


117 Develop a module delivery option that uses the Gravel infrastructure, ROP E-5 All
existing Oliktok Dock and staging pad to avoid module delivery
the need to construct an MTI.
118 Minimize the footprint of the gravel mine based Gravel infrastructure, ROP E-5 All
on amount of gravel needed (i.e., less gravel mine site
needed for Option 3).
119 Reduce potential fugitive methane emissions by Pipelines None Air quality; Climate
processing and compressing produced gas for change
reinjection and gas lift to enhance production.
120 Minimize vented methane gas volumes by Pipelines None Air quality; Climate
initially depressurizing pipelines to the change
production system, flare, and then purge lines
with nitrogen prior to opening. By using
nitrogen sweep and purge, little to no natural
gas should be released when opening the
equipment to atmosphere.
121 Use flaring to support process safety only (no Processing facility None Air quality; Climate
flaring for production). change
122 Use electric solenoids or instrument air driven Processing facility None Air quality; Climate
pneumatics instead of natural gas driven change
pneumatics.
123 Use high efficiency turbines at the WPF (versus Processing facility None Air quality; Climate
older frame style units employed at Prudhoe change
Bay and Kuparuk.
124 Use waste heat from the power generation Processing facility None Air quality; Climate
turbines at the WPF to provide building and change
process heat for the WPF. No gas fired process
heaters would be required during normal
operations.
125 Use waste heat from fuel gas fired drill site Drill site facilities None Air quality; Climate
heaters to supply building heat at drill sites to change
reduce electrical demand.


126 Prevent hydrocarbon emissions by installing Processing facilities and None Air quality; Climate
vapor recovery units on hydrocarbon process storage tanks change
tanks and vessels to prevent hydrocarbon
emissions. (Note: these are process vessels and
not storage vessels in the regulatory sense of the
word. The infield flowlines, processing facility,
and sales pipeline design obviate the need for
permanent oil storage capacity onsite.)
127 Use three-phase (gas, oil, and water) lines, Pipelines None Air quality; Climate
which flow from each drill site to the Willow change; Spill risk
processing facility, and gas injection pipelines
which flow from the Willow processing facility
to each drill site, instead of gas gathering lines.
Both types of overland pipelines have
connections that are welded by design and
largely avoid flanged connections minimize
potential for leaks. These pipelines would
employ the same leak detection surveys as the
existing Alpine development (i.e., the lines will
be surveyed in accordance with state regulations
18 AAC 75.080).
128 Conduct leak surveys (including methane) in Processing facilities and 40 CFR 60 Air quality; Climate
accordance with New Source Performance pipelines change
Standard (40 CFR 60 OOOOa or OOOOb
[whichever regulation is applicable at the
time]). Recycle the produced gas, not used for
fuel or safety flare, and inject it for gas lift for
reservoir pressure support (see also measure
number 119).
129 Prior to WPF commissioning, use gas from the Processing facility None Air quality; Climate
GMT-2 production pipeline to power the change
Willow Operations Center turbine via fuel gas
rather than diesel fuel, which would produce
less emissions than diesel fuel.
130 Use centrifugal compressors equipped with dry Processing facility None Air quality; Climate
seals. Dry seal systems minimize methane change
leakage (versus wet seals).
131 Use electric power (from Project gas-fired Processing facility and None Air quality; Climate
turbines) for drilling and completion activities drill site equipment change
(e.g., drill rig and hydraulic fracturing
equipment), versus using diesel fuel powered
units.
132 Capture and reinject produced gas during Processing facility and None Air quality; Climate
drilling, well completions, and flowbacks once drill site equipment change
the wellsite is connected by pipeline to the WPF
to reduce combustion and methane emissions.
133 Voluntarily comply with the Oil and Gas Processing facilities, drill None Air quality; Climate
Methane Partnership, administered by the sites, and pipelines change
United Nations, which aims to improve
methane measurements and drastically reduce
methane emissions through measurement,
reporting, and reduction. The Willow Project
will comply with the OGMP 2.0 guidelines,
which would be subject to verification under the
OGMP.


134 Implement a vehicle management plan (as Vehicles None Air quality; Climate
required under the NSB rezoning ordinance), change
including traffic reduction measures.
135 Use mineral oil-based drilling muds where Well drilling None Air quality; Climate
technically feasible to reduce vented methane change
emissions.
136 Use insulation in gravel roads and gravel pads Gravel infrastructure NSB rezoning Permafrost and gravel
where practicable to reduce the overall ordinance resources; Terrestrial
embankment height and gravel fill volume requirement mammals; Subsistence
requirements while still maintaining thermal
stability of the underlying permafrost.
137 CPAI will institute the following restrictions to Vehicles None Air quality; Birds;
ground-vehicle traffic in the Willow Project Terrestrial mammals;
area (i.e., gravel and ice roads extending Subsistence
south/southwest from GMT-2):
• The maximum speed limit on Willow gravel
roads will be 35 mph to reduce the potential
for vehicular accidents and disturbance of
caribou. Infield roads that are 25 feet wide
will have a maximum speed of 25 mph.
• Periodic traffic closures will be instituted
when groups of 25 or more caribou appear
to be approaching the road and current
traffic exceeds 15 vehicles per hour.
• Wildlife will always have the right-of-way
and vehicle traffic will be slowed or stopped
to allow animals to cross Project roads.
• Bus transportation will be used as the
primary means to transport personnel
between camps and their assigned work
locations, as well as between camps and the
Alpine CD1 airstrip during mobilization and
demobilization.
138 CPAI will institute the same safety access and Gravel roads None Subsistence
use guidelines for Project roads as the operating
Alpine development and Greater Mooses Tooth
facilities.
Note: °F (degrees Fahrenheit); ADEC (Alaska Department of Environmental Conservation); ADF&G (Alaska Department of Fish and
Game); ADNR (Alaska Department of Natural Resources); AOGCC (Alaska Oil and Gas Conservation Commission); BLM (Bureau of
Land Management); BT1 (Bear Tooth 1 drill site); BT2 (Bear Tooth 2 drill site); BT3 (Bear Tooth 3 drill site); CPAI (ConocoPhillips
Alaska, Inc.); DMLW (Division of Mining, Land, Water); EIS (Environmental Impact Statement); ESA (Endangered Species Act); GIS
(geographic information system); GMT-1 (Greater Mooses Tooth 1); GMT-2 (Greater Mooses Tooth 2); HDD (horizontal directional
drilling); LS (lease stipulation); mph (miles per hour); MTI (module transfer island); No. (number); NPR-A (National Petroleum Reserve in
Alaska); NSB (North Slope Borough); OHW (ordinary high water); ROP (required operating procedure); VSM (vertical support member);
WPF (Willow Processing Facility). All cited lease stipulations and required operating procedures are from the National Petroleum Reserve
in Alaska Integrated Activity Plan/Environmental Impact Statement Record of Decision (BLM 2022b).
a Other stipulations include typical State of Alaska or NSB permit stipulations for North Slope activities or typical ESA conservation
measures or LSs or ROPs. The table lists the agency from which the typical stipulation would arise.
3.0 ADDITIONAL MITIGATION MEASURES ADOPTED

In addition to Project design features, LSs, and ROPs applicable to the Project, the following additional mitigation
measures are hereby adopted to further avoid or reduce impacts from the Project. These measures are discussed in
the relevant resource sections in the Willow MDP Final Supplemental EIS, Chapter 3.0, Affected Environment
and Environmental Consequences, and are summarized in Appendix I.1, Avoidance, Minimization, and Mitigation
Technical Appendix, of the Final Supplemental EIS. They were developed based on suggestions from cooperating
agencies, stakeholders, public comments, and BLM staff raised during both the initial Willow MDP EIS process

and the Willow MDP Supplemental EIS process. Some of these requirements were previously adopted in the 2020
Willow MDP ROD. These measures have been reviewed and updated as appropriate. Previous requirements that
have been edited consistent with input provided from BLM specialists, cooperating agencies, stakeholders, and
the public as well as requirements that are newly adopted as part of the Supplemental EIS process are marked
with an asterisk.
Some clarifications and minor modifications were made to the additional mitigation measures adopted in this
ROD and may not verbatim match the additional suggested mitigation measures as described in the Final
Supplemental EIS in Appendix I.1. These edits were primarily made to correct sentence structure, grammatical
errors, and wording, and in a few instances technical refinements were made for accuracy, to improve
implementation, and ensure enforceability. The rationale for any substantive changes to mitigation measures (e.g.,
a portion of the suggested standard/requirement), is included in Tables 4.1, 4.2, and 4.3 in Section 4.0 of this
appendix.
The Proponent may propose a deviation from these requirements/standards as described in the Final Supplemental
EIS. If experience or additional study indicate that a requirement/standard is not achieving or is unlikely to
achieve its protective objective or will be less effective than the use of more recently proven technology or
techniques, BLM may allow or require other measures to meet the objective. This will be accomplished at the
activity-level permitting stage and under the terms of the LS or ROP exception process outlined in the NPR-A
IAP/EIS ROD.
Measure 1: Fugitive Dust Control Plan

Objective: Control fugitive particulate matter (PM) emissions from the Project.
Requirement/Standard: Implement a Fugitive Dust Control Plan to mitigate impacts from fugitive PM emissions
from the Project. This plan will require regular watering of pads and unpaved roads, establish speed limits on
gravel roads, and several other measures to reduce fugitive dust emissions and impacts. See Final Supplemental
EIS Appendix I.3, Dust Control Plan, for additional details. The Dust Control Plan details the frequency of
compliance monitoring and reporting, as well as the frequency of control measures.
Potential Benefits and Residual/Unavoidable Impacts: Dust remains a concern on the North Slope and was a key
issue during scoping. The Project air quality analysis assumed that Proponent would provide a Dust Control Plan.
Air quality modeling indicated that PM2.5 would be 85% of ambient air quality standards (AAQS) at the Project
site and 22% of AAQS in Nuiqsut. Modeling indicated that PM10 would be 89% of AAQS at the Project site and
34% of AAQS in Nuiqsut.
Measure 2: Flight Paths

Objective: Minimize effects of aircraft noise on Nuiqsut.
Requirement/Standard: Alter flight paths (fixed-wing and helicopter) to avoid Nuiqsut.
Potential Benefits and Residual/Unavoidable Impacts: Minimize effects of aircraft noise on residents of Nuiqsut
and subsistence users in the area.
Measure 3: Blasting Hours

Objective: Minimize effects of blasting noise on Nuiqsut residents.
Requirement/Standard: Limit blasting at the Tiŋmiaqsiuġvik mine site to the hours of 10:00 a.m. to 8:00 p.m.,
notify residents, and strive to adhere to a consistent daily schedule.
Potential Benefits and Residual/Unavoidable Impacts: Minimize noise to hours when sleep would be least likely
to be affected. Provide a stated window when noise from blasting would not occur, so that residents can plan
activities accordingly.

Measure 4: Visual Impact Management

Objective: Minimize effects to visual resources from the Project.
Requirement/Standard: Include the following in the plan to minimize visual impacts (plan is required as per ROP
E-17): Use a dull finish on tall metal structures not otherwise painted, including but not limited to
communications towers and drill rigs. This measure does not apply to ancillary, external building components,
including but not limited to clamps, pipes, and vents.
Potential Benefits and Residual/Unavoidable Impacts: Minimize effects to visual resources from the Project.
Measure 5: Project Lighting*

Objective: Minimize light visible from outside of Project facilities.
Requirement/Standard: Implement lighting controls to turn off exterior lighting at satellite pads and other
unoccupied facilities when personnel are not present, between August 1 and October 31.
Potential Benefits and Residual/Unavoidable Impacts: Minimize light visible from outside of Project facilities to
reduce contrast from glare and artificial lighting and reduce effects to visual aesthetics. This measure will also
reduce effects to birds that may be disoriented or attracted to the light and mitigate the collision risk to birds.
Measure 6: Culvert, Bridge, and Pipeline Stream Crossings

Objective: Ensure Project culvert, bridge, and pipeline stream crossings are designed to adequately pass flood
events and minimize likelihood of structure failure, erosion, backwatering, etc.
Requirement/Standard: Final Supplemental EIS Appendix E.8A (Water Resources Technical Appendix) provides
detail about culvert, bridge, and pipeline design and how that influences potential effects to water resources.
Additional measures to reduce impacts created by culvert, bridge, and pipeline crossings, will include:
1. Unless a more appropriate method is available, when estimating flood-peak discharge at locations within
the Fish Creek, Judy (Iqalliqpik) Creek, and Ublutuoch (Tiŋmiaqsiuġvik) River basins, use a weighted
average from a single station analysis of the BLM long-term monitoring station data on each of these
streams and the Shell regression equations (Appendix E.8A, Water Resources Technical Appendix). Weight
the results of the two computations based on the uncertainty associated with each estimate.
2. As appropriate, consider both 1) snow- and ice-impacted conditions and 2) ice-free conditions in the
hydraulic design of bridges, culverts, and pipeline river crossings. Cross-section data at the time of the peak
stage and peak discharge that are available for many rivers and streams indicate that the water surface
elevation (WSE) was affected by snow and/or ice blockage. Based on the available information, develop
designs that will perform satisfactorily during the design event considering both the possibility of open
water conditions and the possibility that snow and ice blockage is occurring at the time of the design event.
At a minimum, the magnitude of the blockage used in the designs will be similar to the magnitude of the
blockage that has been observed.
3. At a minimum, design stream culverts to perform satisfactorily for all flood events up to and including the
50-year event. The headwater-to-diameter ratio at the maximum design condition will be no greater than
1.0.
4. Identify the locations requiring cross-drainage culverts during spring breakup prior to construction, by
noting all locations where water is flowing over the proposed alignment. This is necessary because it is
often not possible to determine where water flowing in polygon troughs will cross the alignment during a
summer or fall inspection. At the same time, identify the ends of the proposed culverts and the invert
elevation of the ends of the culvert in order to maintain the flow in the historical flow path.
5. At a minimum, design road bridges to pass the 50-year flood-peak discharge with a minimum of a 3-foot
freeboard (assuming snow and ice conditions have been considered in estimating the design WSE). Design
for bridge foundation scour equal to the maximum scour depth produced by floods up through a magnitude
equal to the 100-year flood event, and a geotechnical design practice safety factor of 2 to 3. Check the
bridge design using a superflood and a geotechnical design practice safety factor of 1. The superflood is
defined as the 500-year event, 1.7 times the magnitude of the 100-year event, or the overtopping flood,

whichever is the least. These are standard criteria used by Alaska Department of Transportation and Public
Facilities for bridges on the North Slope in non-designated flood hazard areas.
6. At a minimum, design pipeline river crossings to perform satisfactorily for all floods up to and including
the 200-year event (including crossings on bridges or vertical support members [VSMs]). This is the
magnitude of the design event that has typically been used for common carrier pipelines on the North Slope
and a higher level of design than is being proposed for the Project.
7. Start bridge and culvert hydraulic computations sufficiently downstream so that the downstream boundary
assumptions do not affect the performance of the proposed design. Consider the U.S. Army Corps of
Engineers (1986) report “Accuracy of Computed Water Surface Profiles” in determining the location of the
downstream boundary for hydraulic computations.
8. If the highest observed WSE or high water mark is higher than the predicted 50-year WSE at a culvert,
bridge, or pipeline, re-evaluate the design WSE to confirm that snow and ice blockage and other details of
the computation are accurate. Given the conditions on the North Slope, it is unlikely that high water marks
from a 50-year flood or greater will be recognizable unless it occurred in the last 10 to 20 years.
Additionally, it is improbable that a 1- to 5-year field program will experience a 50-year flood. It is more
likely that snow and ice blockage greater than accounted for in the model used to predict the 50-year WSE
or an error in the downstream boundary condition used in the model has occurred.
9. Pipelines will be designed with a minimum of 3 feet of freeboard for open water conditions and a minimum
of 1 foot of freeboard for ice-affected conditions. Additional freeboard will be applied if uncertainty in the
magnitude of the design discharge, hydraulic computations, or ice-affected analysis warrants.
10. Where an aboveground pipeline crossing is immediately upstream from a road, backwater from the road
during the pipeline design event will be considered when setting the bottom of pipe elevation. Additionally,
if the road is designed for a smaller flood than the pipeline, the changes in hydraulic conditions at the
pipeline as a result of the road wash-out will be considered (i.e., changes in location of the concentrated
flow and the impact on erosion at the VSMs).
11. Where an aboveground pipeline crossing is immediately downstream from a road, the impact of the road on
where water will be flowing and the velocity of the water at the pipeline VSMs will be considered.
Additionally, if the road is designed for a smaller flood than the pipeline, the changes in hydraulic
conditions at the pipeline as a result of the road wash-out will be considered (i.e., changes in the location of
the concentrated flow and the impact on erosion at the VSMs).
Potential Benefits and Residual/Unavoidable Impacts: This measure will minimize the likelihood of structure
failure, erosion, backwatering, and potential spills (from pipeline crossing failures). Structure failures can impact
a number of different human, physical, and biological resources.
Measure 7: Ice Infrastructure

Objective: Minimize effects to waterbodies from Project ice infrastructure.
Requirement/Standard: This measure provides additional specificity to ROP C-3. Breach ice road crossings
sufficiently that ice from crossing will not contribute to ice jams or increase snow and ice blockage during spring
breakup. Consistency with this requirement will generally be demonstrated by employing such measures as the
following, or similarly protective measures implemented by the Proponent or its contractors:
 Ice slot widths proportional to channel widths.
 Ice slots wide enough to prevent damming and overbank flooding upstream of the crossing.
 Ice slots located along the crossing such that they connect the deep upper section of the channel with the
deep lower section of the channel.
 Inspect ice slots during the early breakup season to ensure the bridge crossing is breached.
 Note problems with damming so that improved slotting measures can be used at the crossing in subsequent
years.
 Avoid placing multi-season ice pads in floodplains (e.g., construction pads at the mine site).
Potential Benefits and Residual/Unavoidable Impacts: Minimizes potential effects of ice dams and backwatering
due to ice in stream channels or floodplains.

Measure 8: Colville River Horizontal Directional Drilling Crossing Construction

Objective: Minimize effects to the Colville River from Project horizontal directional drilling (HDD) crossing.
Requirement/Standard: Prior to HDD construction, provide a monitoring and response plan for determining if
drilling mud is being lost to formation or the surface (i.e., making it to the river bottom) during drilling. The plan
will include:
 Amount of drilling mud pumped into the drill hole.
 Amount of drilling mud returned back up the drill hole.
 Other monitoring measures such as turbidity monitoring in the river.
 Response measures to be taken in the event mud is lost.
The plan will be submitted to the BLM Arctic District Authorized Officer for awareness 60 days prior to the start
of HDD construction.
Potential Benefits and Residual/Unavoidable Impacts: This measure will ensure that any loss of drilling mud
would be documented and crews would be prepared to respond. HDD drilling mud will be limited to water-based
varieties, without petroleum products.
Measure 9: Surveillance of Stream Crossings

Objective: Ensure Project structures at stream crossing are functioning properly.
Requirement/Standard: Provide annual surveillance of bridge, culvert, and pipeline river crossings for the first 3
years to confirm that structures are functioning properly and provide maintenance as required. Results of this
monitoring will be made available to the BLM Authorized Officer upon request. After the first 3 years
surveillance would be done every 3 years.
Potential Benefits and Residual/Unavoidable Impacts: This measure will help ensure that bridge, culvert, and
pipeline river crossings are functioning properly and help minimize effects to waterbodies (and potentially aquatic
species, if present) should a maintenance issue occur. Required surveillance will ensure that issues are detected
and addressed in a timely manner.
Measure 10: Option 3 Colville River Crossing Data and Adaptive Management Plan
Objective: Design and implement an ice bridge crossing of the Colville River that is informed by current ice and
water data and allows passage of fish and water as needed, while minimizing effects to all resources.
Requirement/Standard: For the Ocean Point crossing site, prepare an Adaptive Management Plan based on
baseline data that addresses potential unanticipated conditions and events, such as surface water flow blockages.
The plan will describe measures to respond to such issues. The plan will be submitted to the BLM Authorized
Officer for awareness prior to winter construction.
Potential Benefits and Residual/Unavoidable Impacts: An Adaptive Management Plan for the Colville River
Crossing will minimize effects to the river and aquatic species if they are present during construction. Because
few data are available for Ocean Point, this measure requires a plan for how to manage for different conditions at
the time of construction.
Measure 11: Boat Ramps Maintenance Plan

Objective: Minimize impacts to streams from Project boat ramps.
Requirement/Standard: Develop a maintenance plan for the boat ramps to ensure long-term viability and use of
the site(s) while minimizing impacts to the adjacent waterbodies; initial plan to be submitted to the BLM
Authorized Officer 60 days prior to initiating the first year’s maintenance activities. Any substantive changes to
the maintenance plan will be submitted to BLM prior to initiation of maintenance activities impacted by those
changes. The plan will include such measure as:
 Determine if erosion mitigation features or options in engineering design of boat ramp(s) are needed to
prevent or minimize erosion potential at the boat ramp(s) and along adjacent riverbanks. Describe the

evaluation that was completed to determine if erosion control is needed and what type of features are
included in the final design.
 Identify entity responsible for site maintenance.
 Describe annual maintenance (grading) of parking pads, turning pads, access ramps, and road access.
 Identify the gravel source for reinforcement of boat ramps and pads when necessary. Describe the location
and quantity of gravel available and the frequency of how often the need for additional gravel will be
evaluated.
 Include regular clean-up of pads and surroundings, including back-haul of trash to suitable disposal site.
 Describe that spills will be removed or mediated per the Project’s spill plan.
Potential Benefits and Residual/Unavoidable Impacts: A maintenance plan for the boat ramps will increase the
likelihood that the ramps will be maintained and reduce erosion or sedimentation of the stream.
Measure 12: Terrestrial Invasive Species Protections

Objective: Minimize transport or introduction of invasive species due to the Project.
Requirement/Standard: As part of the Invasive Species Prevention Plan required in ROP M-2, as applicable,
include the following at a minimum:
1. Use existing vehicle and equipment wash stations and inspect vehicles and equipment for organic matter
(e.g., invasive species) prior to moving equipment into the NPR-A to reduce the risk of introducing
invasive species. Clean tires and wheel wells so they are free from soils, seeds, and plant parts.
2. Provide stations to clean footwear and gear so they are free from soils, seeds, and plant parts.
3. Provide training to employees and contractors in identification, control, and prevention of known invasive
plant species.
Potential Benefits and Residual/Unavoidable Impacts: Invasive species can have broad-ranging effects on
numerous species and habitats, food chains, and food resources for aquatic species. Prevention of introduction is
typically easier than control once invasive species are established. This measure would help minimize the
likelihood of transportation and introduction of terrestrial invasive species.
Measure 13: Overwintering Fish Habitat

Objective: Avoid crossing overwintering fish habitat with ice infrastructure.
Requirement/Standard: Identify overwintering fish habitat (maximum water depths, particularly free- water depth
under ice cover) in the Colville River at Ocean Point and other streams in the NPR-A that might intersect the
Option 3 (Colville River Crossing) ice road. Avoid crossings of potential overwintering habitat whenever
practicable.
Potential Benefits and Residual/Unavoidable Impacts: Because overwintering fish habitat is limited on the North
Slope, avoiding this limited resource would help minimize impacts to overwintering fish.
Measure 14: Aquatic Invasive Species Prevention

Objective: Prevent introduction or transportation of aquatic invasive species.
Requirement/Standard: Adopt National Marine Fisheries Service (NMFS) BMPs for invasive species prevention
in essential fish habitat (Limpinsel, Eagleton et al. 2017) within the NPR-A:
 Uphold fish and game regulations of the Alaska Board of Fisheries (AS 16.05.251) and Board of Game (AS
16.05.255), which prohibit and regulate the live capture, possession, transport, or release of native or exotic
fish or their eggs.
 Adhere to regulations and use best management practices outlined in the State of Alaska Aquatic Nuisance
Species Management Plan (ADF&G 2002).
Potential Benefits and Residual/Unavoidable Impacts: Aquatic invasive species can have broad-ranging effects on
numerous species and habitats, food chains, and food resources for aquatic species. Prevention of introduction is
typically easier than control once invasive species are established. This measure would help minimize the
likelihood of transportation and introduction of aquatic invasive species.

Measure 15: Bird Collisions*

Objective: Minimize collisions of birds with Project infrastructure.
Requirement/Standard: Implement the following as much as practical:
 Locate mast poles away from the pad edge.
 Minimize the number and height of towers.
 Restrict speed limits to minimize collision hazard and dust production (35 miles per hour [mph] except in
areas of congestion, on bridges, and on pads, which will be slower). All speed limits shall be prominently
signed.
 Minimize barge and support vessel speed to reduce potential for bird strikes. (Vessels will travel at speeds
slower than 14 knots [16 mph] as per the Endangered Species Act Section 7 consultation with U.S. Fish
and Wildlife Service [USFWS].)
 Reduce window reflectivity to minimize bird strikes by using window treatments on externally facing
windows on buildings. This measure expands the visibility requirements in ROP E-10. Also see Measure 5:
Project Lighting.
 Communication towers shall be monopoles without guy wires where feasible. In instances where it is not
feasible to use monopoles, all guy wires shall be marked with reflectors to deter bird collisions.
 For tower structures exceeding 200 feet in height with Federal Aviation Administration (FAA) required
light, use white (preferable) or red strobe lights. The strobed should be set at a minimum number of flashes
per minute allowable by the FAA. The use of solid red or pulsating warning lights at night should be
avoided, if possible.
Potential Benefits and Residual/Unavoidable Impacts: Reducing the collision hazards will reduce mortality and
injuries for all species of birds in the analysis area. Controlling incidental light and reducing reflectivity of
windows will reduce the potential for collisions and energetic costs from attraction and disorientation of flying
birds during migratory movements during low visibility. Bird collisions will continue to occur, but rates of injury
and mortality will likely be decreased.
Measure 16: Bird Disturbance*

Objective: Minimize bird habitat alternation and disturbance of birds from the Project.
Requirement/Standard: Implement the following:
 Wherever practical, route ice roads around identified yellow-billed loon nesting sites and nesting lakes to
avoid vegetation compaction at nesting sites and delayed melt-out of nesting lakes.
 Haze birds out of the blast area at the mine site before blasting (if resident birds are present in winter).
 Consistent with the goals of ROP E-18, plan construction activities and road improvement activities to
minimize noise impacts as much as practical between June 1 and July 31 when birds on nests would be
unable to move away from the disturbance.
Potential Benefits and Residual/Unavoidable Impacts: Minimizing noise, air traffic, and helicopter use will reduce
disturbance, potential loss of nests, disruption of broods, and energetic costs to molting waterfowl.
Measure 17: Caribou Crossings*

Objective: Minimize effects to caribou movement due to Project infrastructure.
Requirement/Standard: ROP E-7 describes requirements related to caribou ramps over pipelines or buried
pipelines. Measure 17: Caribou Crossings designates locations for these, specifically: along the access road just
west of the intersection of the infield and access roads, and similarly along the access road just east of the
intersection of the infield and access roads.
Potential Benefits and Residual/Unavoidable Impacts: Caribou are generally able to cross pipelines elevated to 7
feet, but ramps could be effective in areas where caribou movements are funneled towards pipelines close to roads
with high traffic levels (Lawhead, Parrett et al. 2006). Caribou may still have difficulty crossing roads with high
traffic volumes.

Measure 18: Aircraft Use Plan

Objective: Minimize effects to caribou movement due to Project air traffic.
Requirement/Standard: ROP F-1 requires the use of an Aircraft Use Plan. Measure 19: Aircraft Use Plan clarifies
items that will be included in the plan for the Project. The plan will include the following:
 Minimize Q400 traffic between Alpine and Willow during calving (May 20 to June 20) to reduce impacts to
caribou. Q400 traffic between Willow and Kuparuk or Deadhorse is necessary and would be allowed.
 Plans to minimize the disturbance to calving caribou (description of areas avoided, how flight numbers were
minimized, and that low altitude flights were avoided or limited).
Potential Benefits and Residual/Unavoidable Impacts: Limiting high-decibel aircraft activity will help lower the
amount of disturbance and displacement of caribou that occurs near the airstrip, especially during calving.
Because some flights between Willow and Kuparuk or Deadhorse will still occur in addition to general activity at
the airstrip area, some displacement of calving caribou is still likely.
Measure 19: Deicing Materials

Objective: Minimize effects to wildlife from Project deicing materials.
Requirement/Standard: Use propylene glycol for deicing, except in extreme weather events.
Potential Benefits and Residual/Unavoidable Impacts: This will reduce use of toxic materials and thereby reduce
potential exposure of wildlife and subsistence users.
Measure 20: Community Winter Access Trail Coordination

Objective: Minimize effects from the Project to users of the Community Winter Access Trail (CWAT).
Requirement/Standard: Develop and implement a coordination plan with other stakeholders who are permitted to
use the CWAT snow road (i.e., North Slope Borough [NSB] residents) by BLM to prevent access conflicts during
sealift module movement across the Colville River.
Potential Benefits and Residual/Unavoidable Impacts: The CWAT was issued as a 5-year right-of-way (ROW) to
the NSB with the right to renew. Other private users and companies hauling freight across this route will be
required to coordinate their use with both the NSB and CPAI. There are usually two to three commercial freight
hauling efforts each winter. Coordination with other ROW holders and local residents who may use the route will
facilitate improved communication and use requirements in the permits of future ROW applicants.
Measure 21: Subsistence Access*

Objective: Design and maintain subsistence boat ramps, pullouts, subsistence tundra access ramps, and bridges so
they are safe and effective for community members thereby minimizing impacts to subsistence access.
Requirement/Standard: Implement the following as much as practicable:
 Ramps shall be designed such that the top of the ramp is level and long enough or situated in such a way to
accommodate snowmachines pulling sleds without having to enter the associated pull out or adjacent road.
Warning signs will be placed on the adjacent roadway approaching the subsistence ramp/pullout to warn
drivers of the potential for vehicles (e.g., snowmachines, all-terrain vehicles) crossing the road.
 Materials and equipment shall not be staged on gravel road pullouts or in such a way as to block
subsistence ramps or the roadway view for subsistence ramp users.
 Operators will install signs at roadway pullouts stating, “Equipment and Materials Shall Not be Staged
Here”.
 The applicant will provide training (as part of orientation program required by ROP I-1) on the importance
of maintaining clear and safe areas around pullouts and subsistence ramps.
 Subsistence ramp locations will be made available to local search and rescue groups (e.g., Nuiqsut, NSB)
as GPS coordinates and on published maps.
 Project bridges will be designed to ensure adequate clearance for safe passage for boaters travelling along
waterways.

Prior to construction CPAI shall continue to consult with local subsistence users and community organizations
regarding the appropriate design and location of subsistence boat ramps, pullouts, subsistence tundra access
ramps, and bridges. CPAI shall continue to consult with other operators regarding other boat ramp projects on the
North Slope that may inform future designs.
Potential Benefits and Residual/Unavoidable Impacts: Residents will be more likely to use Project roads if they
are easier to access and tundra access ramps are in locations that ease use. Allowing potential users of the access
ramps a role in ramp location and design will increase likelihood that the ramps will provide a locally accepted
mechanism for leaving the road surface and accessing tundra that is safe, feasible, and can minimize impacts to
subsistence access and aid in search and rescue missions. Regular meetings with local residents who use the roads
will facilitate improved design features or other suggestions that can be incorporated to make use of the road,
pullouts, and ramps safer and more effective for users and prevent tundra damage.
Measure 22: Continued Coordination with Local Tribe*

Objective: Minimize effects from the Project to the community of Nuiqsut.
Requirement/Standard: Attend government-to-government meetings between the Native Village of Nuiqsut and
BLM, as requested by Native Village of Nuiqsut, to discuss issues and resolution strategies throughout the life of
the Project.
Potential Benefits and Residual/Unavoidable Impacts: Regular meetings with the community and BLM will
facilitate improved communication and early identification of potential issues that may affect the community. It
will allow discussion of strategies to resolve concerns and provide the community with a platform for dialog
throughout the life of the Project.
Measure 23: Air Quality Monitoring*

Objective: Collect additional air pollutant data within Willow project area and in Nuiqsut and make the data
available to the public.
Requirement/Standard: Install at least one additional air quality monitoring station within the Willow project area.
All air quality monitoring stations shall operate within the following parameters:
 Monitor criteria air pollutants and volatile organic compounds for the life of the project as part of air
quality monitoring plan (required by ROP A-10). Monitoring protocol subject to review by the AO in
consultation with appropriate federal, State, and/or local agencies. The measured concentrations will be
made available as close as technically possible to real time for the community of Nuiqsut and the public at
large.
 Monitoring of hazardous air pollutants and polycyclic aromatic hydrocarbons shall be completed once
every 5 years throughout the life of the project. After two reporting cycles, CPAI may request a waiver for
hazardous air pollutants and polycyclic aromatic hydrocarbons monitoring from the AO.
Potential Benefits and Residual/Unavoidable Impacts: Impacts to air quality from oil and gas development
remain a key concern among North Slope communities as was indicated during scoping. This measure provides
public assurance that the project, in combination with other activities in the area are not causing the air quality in
Nuiqsut to degrade.
Measure 24: Use of Unmanned Aerial Vehicles*

Objective: Reduce impacts to wildlife and subsistence use.
Requirement/Standard: Use unmanned aerial vehicles (i.e., drones) to conduct inspections and surveys to the
greatest extent practicable to reduce impacts to wildlife and subsistence users
Potential Benefits and Residual/Unavoidable Impacts: Use of unmanned aerial vehicles (UAV) could reduce the
number of flights needed to conduct surveys and inspections in support of project activities and operations
thereby minimizing the impact to wildlife, especially caribou, and subsistence users from noise and presence of
overhead flights. Current limitations to UAV use (e.g., short battery life in arctic conditions, inclement weather,
FAA requirements to maintain UAV within line of sight of pilot) preclude their use for all inspections and surveys

within the Project Area. Studies have shown that UAVs have not resulted in a large effect on captive caribou
though there remains potential for effects to caribou (Christie et al. 2016).
Measure 25: Polar Bear Maternal Den Detection Surveys *

Objective: Minimize impacts to denning polar bears.
Requirement/ Standard: For each year in which winter project activities will take place, permittee will conduct
two airborne infrared den detection surveys for polar bear dens prior to initiating those activities.
Potential Benefits and Residual/Unavoidable Impacts: The use of airborne infrared sensors has proven to be an
effective means of locating maternal polar bear dens during den detection surveys. However, this survey
methodology does not provide perfect detection, where occupied maternal dens are sometimes missed in pre-
operations surveys. Using two airborne infrared surveys, conducted over the same area would substantially reduce
the potential for missed maternal polar bear dens during den detection surveys. If maternal polar bear dens are
identified, operators would coordinate with USFWS on mitigation measures specific to the den site location and
adjacent activities.
Measure 26: Use of Surface Miner*

Objective: Reduce impacts from blasting at the Willow Tiŋmiaqsiuġvik Mine Site.
Requirement/Standard: CPAI will evaluate the use of a “surface miner” (a track-driven surface shaving device for
the selective mining of hard or soft material) at the Tiŋmiaqsiuġvik mine site to develop the gravel resource.
CPAI will use a surface miner at the Kuparuk Mine Site during the first year of winter construction activities and
shall provide a report to BLM on the efficacy of this equipment in North Slope conditions no later than June of
the following year. The report shall describe how the equipment was used, any engineering or logistical
challenges of using this equipment and steps taken to adapt the surface miner for use in North Slope operations.
BLM specialists may conduct on the ground inspections to observe the surface miner during use. If the surface
miner is determined to be feasible as an alternative to blasting, the BLM may require its use at the Willow Mine
Site.
Potential Benefits and Residual/Unavoidable Impacts: If feasible for continued use, the use of the surface miner
would reduce the impacts of blasting at the gravel mine site (blasting would still be required to remove
overburden). The noise associated with blasting can impact a variety of wildlife species (e.g., caribou and
migratory birds) as well as local subsistence users.
Measure 27: Protections for Teshekpuk Lake Area *

Objective: Permanently protect the most important habitat areas for the maternal and migrating caribou of the
Teshekpuk Caribou Herd, including Teshekpuk Lake, a buffer around the lake, and the migration corridors to the
east and northwest.
Requirement/Standard: BLM will develop compensatory mitigation that provides durable, long-term protection
for the Teshekpuk Caribou Herd to fully offset impacts of the project on that Herd, to include protecting the
surface area of Teshekpuk Lake, a buffer along all shores of the lake, and the K-10 Caribou Movement
Corridors/K-16 Deferral Areas (under Alternative E in the 2020 National Petroleum Reserve in Alaska Integrated
Activity Plan Final Environmental Impact Statement) using existing statutory, management or administrative
authorities, with a focus on restricting future leasing or surface development in those areas.
Potential Benefits and Residual/ Unavoidable Impacts: To off-set identified impacts in the Greater Mooses Tooth-
1 (GMT1) Project, including major impacts to subsistence uses that cannot be fully mitigated by avoidance and
minimization, the 2015 GMT1 ROD required CPAI to provide $8 million to BLM to establish a compensatory
mitigation fund, including the development and implementation of a landscape-level Regional Mitigation Strategy
(RMS) for the Northeastern NPR-A region. Additionally, Supplemental Best Management Practice 1--
Establishment of Compensatory Mitigation Fund and Regional Mitigation Strategy directed the BLM to prepare
the RMS to serve as a roadmap for mitigating impacts from GMT1 and future projects enabled or assisted by the
existence of GMT1. The BLM finalized the RMS in August of 2018. While specific to the GMT1 project and not
intended to establish a precedent for future projects in the NPR-A or any particular methodology for

compensatory mitigation, the RMS was intended to serve as a mitigation roadmap for future projects, like the
Willow Project, that are enabled or assisted by the existence of GMT1. RMS Table 1, “Potential Mitigation
Projects and Project Locations”, Mitigation Objective 3 “Sustain and enhance the functionality of the ecological
system,” (emphasis in original), describes a potential mitigation project to “Establish conservation easements and
voluntary limits on use and occupancy of existing leases” in the potential project location of, among others, the
Teshekpuk Lake Special Area and vicinity.
In its February 23, 2023 letter to Secretary Haaland regarding its comments on the Final Supplemental EIS,
Kuukpik Corporation noted that
Because Willow will affect the Teshekpuk Lake Caribou Herd (TLCH) more than any other subsistence
resource, Kuukpik strongly supports BLM’s proposal to “develop compensatory mitigation that provides
durable, long-term protection for the Teshekpuk Lake Caribou Herd to fully offset impacts of the Project
on that Herd….” Successfully implementing this mitigation measure will virtually eliminate the risk of
further development in the most important caribou habitat areas—areas that will become even more
important after Willow is constructed.
Kuukpik Corporation made two follow-on recommendations. One, that the Department clarify that the “durable
and long-term protection” would be more than restrictions included in an NPR-A Integrated Activity Plan, and
two, that the buffer for the area to be protected be clarified to have support by conservation and subsistence-
minded stakeholders that a sufficiently large area will be protected and development-oriented stakeholders that the
restrictions are justified and not excessive.
Recognizing the importance of this matter, the BLM is directed to take action to further this mitigation measure.
The BLM shall explore creating a bi-lateral or multi-lateral conservation instrument to provide protections for the
Herd and its key habitat for the duration of the Project’s impacts. Within 120 days, the BLM should provide a
report to the Principal Deputy Assistant Secretary of Lands and Minerals Management that addresses the
following: who would hold the instrument; the scope of the lands to be protected; and the types of protections,
with a focus on restricting future leasing and/or surface development. The report should contain a discussion of
BLM’s findings and recommendations with respect to this conservation instrument, including a proposal for
stakeholder engagement and implementation, if approved.
One benefit unique to a conservation instrument is to provide local community entities greater ability to directly
influence the pace, scale and location of future leasing activities and/or surface development impacting an
important subsistence resource.
4.0 ADDITIONAL MITIGATION MEASURES CONSIDERED BUT

NOT ADOPTED
The decision in this ROD includes the adoption of all practicable means to avoid or minimize environmental harm
consistent with the purpose and need of the action, including potential impacts associated with cumulative
impacts. BLM provides the following explanations for not adopting the following mitigation measures considered
in the Willow MDP Final Supplemental EIS (Tables 4.1, 4.2, and 4.3). All proposed mitigation measures
considered in the Final Supplemental EIS are described in Appendix I.1 of the Final Supplemental EIS.


4.1 Additional Suggested Avoidance, Minimization, or Mitigation Considered in the 2020 Willow MDP Environmental Impact Statement
Table 4.1 summarizes additional suggested avoidance, minimization, or mitigation measures considered in the 2020 Willow MDP EIS. Table 4.2 summarizes cooperating agency suggested mitigation measures developed for the Willow MDP
Supplemental EIS.
Table 4.1 Additional Suggested Avoidance, Minimization, or Mitigation from the 2020 Willow MDP Environmental Impact Statement
Affected Additional Suggested Avoidance, Minimization, or Mitigation Mitigation Rationale For or Against Adoption
Resource(s) Adopted
(Yes or No)
Air Quality Implement a Fugitive Dust Control Plan to mitigate impacts from fugitive particulate matter emissions from the Project. This plan would require regular Yes See Measure 1.
watering of pads and unpaved roads, enforcing speed limits on unpaved access and haul roads, and several other measures to reduce fugitive dust emissions
and impacts. See Appendix I.3, Dust Control Plan, for additional details.
Soils, Use the following in design of roads and embankments: No The use of geotextiles would not improve the structural integrity of the permafrost or protect
Permafrost, and • Separate native soils from Project fill materials using geotextiles or fabrics permafrost beyond the proposed design. Additionally, during reclamation, fabric could mix
Gravel with gravel and native soil and turn otherwise reusable soil into large volumes of waste that
Resources would need to be hauled outside of the NPR-A to a waste disposal site.
Soils, Use the following in design of roads and embankments: No The mitigation measure would dramatically expand infrastructure footprints, contradicting
Permafrost, and • Use thick embankments and shallow slopes requirements derived from the Clean Water Act to minimize the gravel footprint.
Gravel
Resources
Soils, Use the following in design of roads and embankments: No The adopted alternative and module delivery option do not have an annual ice road.
Permafrost, and • Monitor thermokarsting, depth of active layer, and compression of soil and vegetation in annual resupply ice road footprint, for footprints that are used
Gravel consecutively each year
Resources
Noise Alter flight paths to avoid sensitive areas (such as Nuiqsut) Yes See Measure 2.
Noise Limit blasting to the hours of 10:00 a.m. to 8:00 p.m. Yes See Measure 3.
Visual Include the following in the plan to minimize visual impacts (plan is required as per ROP E-17): No ROP E-17 already requires a plan for approval by BLM that construction of permanent
Resources · Ensure structures are a color that blends in with the background colors of the natural landscape. All colors would be pre-approved by the BLM. facilities best minimize visual impacts, consistent with the visual resource management class
for the lands on which facilities would be located.
Visual Include the following in the plan to minimize visual impacts (plan is required as per ROP E-17): Yes See Measure 4.
Resources • ROP E-7 and CPAI’s design measure 58 (Appendix I.1, Table I.1.2) state that a non-reflective coating would be used on pipelines; that could be expanded
to all metal structures not otherwise painted, including but not limited to communications towers and drill rigs.
Visual Minimize light visible from outside of Project facilities at all times of the year by using lighting fixtures with lamps contained within the reflector and shading Yes See Measure 15 (window shading). Note that as adopted in Measure 15 the words “external
Resources externally facing windows on buildings. This will minimize impacts on visual aesthetics (i.e., reduce contrast from glare and artificial lighting). shading” is replaced with “window treatments” to ensure that this measure is not interpreted
as a requirement for external structures, such as awnings or blinds. Design Measure 51
requires minimization of external visible light year-round, this was updated for the 2022
Willow Supplemental EIS such that the requirement to minimize light from outside of
Project facilities at all times of the year by using lighting fixtures with lamps is sufficiently
met.

Resource(s) Adopted
(Yes or No)
Water Appendix E.8 provides detail about culvert, bridge, and pipeline design and how that influences potential effects to water resources. Additional suggested Yes See Measure 6.
Resources measures to reduce impacts created by culvert, bridge, and pipeline crossings, could include:
• Unless a more appropriate method is available, when estimating flood-peak discharge at locations within the Fish Creek, Judy (Iqalliqpik) Creek, and
Ublutuoch (Tiŋmiaqsiuġvik) River basins, use a weighted average from a single station analysis of the BLM long-term monitoring station data on each of
these streams and the Shell regression equations (Appendix E.8). Weight the results of the two computations based on the uncertainty associated with each
estimate.
• As appropriate, consider both 1) snow- and ice-impacted conditions and 2) ice-free conditions in the hydraulic design of bridges, culverts, and pipeline
river crossings. Cross-section data at the time of the peak stage and peak discharge that are available for many rivers and streams indicate that the WSE
was affected by snow and/or ice blockage. Based on the available information, develop designs that would perform satisfactorily during the design event
considering both the possibility of open water conditions and the possibility that snow and ice blockage is occurring at the time of the design event. At a
minimum, the magnitude of the blockage used in the designs should be similar to the magnitude of the blockage that has been observed.
• At a minimum, design culverts to perform satisfactorily for all flood events up to and including the 50-year event. The headwater-to-diameter ratio at the
maximum design condition should be no greater than 1.0.
• Identify the locations requiring cross-drainage culverts during spring breakup prior to construction, by noting all locations where water is flowing over the
proposed alignment. This is necessary because it is often not possible to determine where water flowing in polygon troughs will cross the alignment during
a summer or fall inspection. At the same time, identify the ends of the proposed culverts and the invert elevation of the ends of the culvert in order to
maintain the flow in the historic flow path.
• At a minimum, design road bridges to pass the 50-year flood-peak discharge with a minimum of a 3-foot freeboard (assuming snow and ice conditions
have been considered in estimating the design water surface elevation). Design for bridge foundation scour equal to the maximum scour depth produced
by floods up through a magnitude equal to the 100-year flood event, and a geotechnical design practice safety factor of from 2 to 3. Check the bridge
design using a superflood and a geotechnical design practice safety factor of 1. The superflood is defined as the 500-year event, 1.7 times the magnitude of
the 100-year event, or the overtopping flood, whichever is the least. These are standard criteria used by Alaska Department of Transportation and Public
Facilities for bridges on the North Slope in non-designated flood hazard areas.
• At a minimum, design pipeline river-crossings to perform satisfactorily for all floods up to and including the 200-year event (including crossings on
bridges or VSM). This is the magnitude of the design event that has typically been used for common carrier pipelines on the North Slope and a higher
level of design than is being proposed for the Project.
• Start bridge and culvert hydraulic computations sufficiently downstream so that the downstream boundary assumptions do not affect the performance of
the proposed design. Consider the U.S. Army Corps of Engineers (1986) report “Accuracy of Computed Water Surface Profiles” in determining the
location of the downstream boundary for hydraulic computations.
• If the highest observed WSE or high-water mark is higher than the predicted 50-year WSE at a culvert, bridge, or pipeline, re-evaluate the design water
surface elevation to confirm that snow and ice blockage, and other details of the computation are accurate. Given the conditions on the North Slope, it is
unlikely that high water marks from a 50-year flood or greater would be recognizable unless it occurred in the last 10 to 20 years. Additionally, it is
improbable that a 1- to 5-year field program would experience a 50-year flood. It is more likely that snow and ice blockage greater than accounted for in
the model used to predict the 50-year WSE or an error in the downstream boundary condition used in the model has occurred.
• Use a freeboard at bridges and pipeline crossings which considers the uncertainty in the magnitude of the design flood, the uncertainty in the hydraulic
computations, and the height of the ice and debris that may be carried by the flood but is not less than 3 feet.
• Where an aboveground pipeline crossing is immediately upstream from a road, backwater from the road during the pipeline design event should be
considered when setting the bottom of pipe elevation. Additionally, if the road is designed for a smaller flood than the pipeline, the changes in hydraulic
conditions at the pipeline as a result of the road wash-out should be considered (i.e., changes in location of the concentrated flow and the impact on erosion
at the VSM).
• Where an aboveground pipeline crossing is immediately downstream from a road, the impact of the road on where water would be flowing and the
velocity of the water at the pipeline VSM should be considered. Additionally, if the road is designed for a smaller flood than the pipeline, the changes in
hydraulic conditions at the pipeline as a result of the road wash-out should be considered (i.e., changes in the location of the concentrated flow and the
impact on erosion at the VSM).
Water Breach ice road crossings sufficiently that ice from crossing would not contribute to ice jams or increase snow and ice blockage during spring breakup. Yes See Measure 7.
Resources
Water Avoid placing multi-season ice pads in floodplains (e.g., construction pads at the mine site). Yes See Measure 7.
Resources
Water Prior to HDD construction, provide a monitoring and response plan for determining if drilling mud is being lost to formation or making it to the river or Yes See Measure 8.
Resources groundwater during drilling.
Water Should any spills occur on the MTI, the affected gravel would be addressed immediately and removed prior to MTI abandonment. No The adopted module delivery option, Option 3, will not have an MTI.
Resources
Water If Option 1 or 2 is selected, place and maintain appropriate navigation aids on the MTI after it is decommissioned (the top of the MTI is expected to drop to or No The adopted module delivery option, Option 3, will not have an MTI.
Resources below the water surface)

Resource(s) Adopted
(Yes or No)
Water Provide annual surveillance of bridge, culvert, and pipeline river crossings to confirm that structures are functioning properly and provide maintenance as Yes See Measure 9.
Resources required.
Water Continue to collect baseline data regarding discharge, ice and liquid water conditions and distribution, and bank conditions on the Colville River near Ocean Yes See Measure 10.
Resources Point throughout winters every year until ice bridge construction so that an ice bridge plan can be drafted that would include exact crossing location for bridge
and ramps, plans for flow and fish passage management (should they be needed), and actions to be taken at the end of ice bridge use (such as slotting). Prepare
an adaptive management plan that provides detail regarding how any unanticipated surface water flow blockages would be identified and corrected as quickly
as possible, to avoid lasting environmental impacts.
Water Include erosion mitigation features or options in engineering design of boat ramp(s) to prevent or minimize erosion potential at the boat ramp(s) and along Yes See Measure 11.
Resources adjacent riverbanks.
Water Develop a maintenance plan for the boat ramps to ensure long-term viability and use of the site(s) while minimizing impacts to the adjacent waterbodies. Yes See Measure 11.
Resources Include the following points at a minimum:
• Identify entity responsible for site maintenance
• Annual maintenance (grading) of parking pads, turning pads, access ramps, and road access
• Maintain a gravel supply (off-site) to reinforce boat ramps and pads when necessary
• Regular clean-up of pads and surroundings, including back-haul of trash to suitable disposal site
Water Before construction and continuing through operations, test and monitor freshwater sources that intersect the Project for hydrocarbons. No Water quality protection and monitoring is the purview of the ADEC. Testing and
Resources monitoring of all freshwater sources that intersect the Project is not reasonable and does not
mitigate known Project effects.
Wetlands and If Alternative C or D is selected, monitor vegetation damage, and compression of soil and vegetation in annual resupply ice road footprint (footprints that are No Alternative C or D was not selected. Selected Alternative does not have an annual ice road.
Vegetation used consecutively each year). Because wetter landscapes show less impact from multiyear ice roads (Yokel, Huebner et al. 2007) and ADNR monitors only
tussock tundra and soil compaction, this suggested measure would focus on non-tussock wetlands (including patterned ground) with a Cowardin water regime
class of Temporarily Flooded, Saturated, or Seasonally Flooded Ground by vegetation type (total live cover of graminoid, shrub, forb, moss) and percentage of
bare soil would be monitored with control points and points within ice road footprints to determine changes.
Wetlands and Use vehicle and equipment wash stations and inspect vehicles and equipment for organic matter (e.g., invasive species) prior to moving equipment west of the Yes See Measure 12.
Vegetation Colville River to reduce the risk of introducing invasive species. Clean tires and wheel wells so they are free from soils, seeds, and plant parts.
Wetlands and Provide stations to clean footwear and gear so they are free from soils, seeds, and plant parts. Yes See Measure 12.
Vegetation
Wetlands and Provide training to employees and contractors in identification, control, and prevention of known invasive plant species. Yes See Measure 12.
Vegetation
Wetlands and Confine loading and unloading of soils for gravel stockpiles to the downwind side of the pile; if piles would be on-site for longer periods of time, seed with No This mitigation would introduce new safety risks. Loading from the downwind side would
Vegetation appropriate vegetation to reduce wind erosion. Wind barriers (such as snow fences) may also be appropriate in some situations. impair the vision of the operator, expose the operator to breathing particulates, and would
result in increased equipment maintenance (air intake). Revegetation can take several years
to establish and would not provide protection from wind erosion in the short time period
desired.
Fish Identify overwintering fish habitat (maximum water depths, particularly free-water depth under ice cover) in the Itkillik River and other tributaries to the Yes See Measure 13. Note that this measure was adopted, but limited to NPR-A, the only BLM-
Colville River that might intersect the Option 3 ice road. Avoid crossings of potential overwintering habitat. managed lands in the Project area.
Fish Adopt best management practices suggested by NMFS for essential fish habitat for invasive species (Limpinsel, Eagleton et al. 2017): Yes See Measure 14.
• Uphold fish and game regulations of the Alaska Board of Fisheries (AS 16.05.251) and Board of Game (AS 16.05.255), which prohibit and regulate the
live capture, possession, transport, or release of native or exotic fish or their eggs.
• Adhere to regulations and use best management practices outlined in the State of Alaska Aquatic Nuisance Species Management Plan (ADF&G 2002).
Fish • Encourage vessels to exchange ballast water in marine waters (in accordance with the U.S. Coast Guard’s voluntary regulations) to minimize the No These marine activities are outside BLM’s direct jurisdiction, but the objective is addressed
possibility of introducing invasive estuarine species into similar habitats. Ballast water taken on in the open ocean would contain fewer organisms, and as part of the NMFS measures being adopted as part of the Section 7 consultation.
these would be less likely to become invasive in estuarine conditions.
• Discourage vessels that have not exchanged ballast water from discharging their ballast water into estuarine receiving waters.
Birds Locate mast poles away from the pad edge. Yes See Measure 15.
Birds Implement lighting controls to turn off exterior lighting at satellite pads and other unoccupied facilities when personnel are not present, between August 1 and Yes See Measure 5.
October 31.
Birds Minimize the number of tall towers. Yes See Measure 15.
Birds Limit water withdrawal to lakes without sensitive fish or breeding yellow-billed loons. No The State of Alaska regulates water withdrawal with restrictions on volumes of water
removed. Proponent water withdrawals from yellow-billed loon lakes will be done in
accordance with permitted ADNR- and ADF&G-authorized limitations.
Birds Route ice roads around identified yellow-billed loon nesting sites and nesting lakes to avoid vegetation compaction at nesting sites and delayed melt-out of Yes See Measure 16.
nesting lakes.

Resource(s) Adopted
(Yes or No)
Birds Restrict speed limits to minimize collision hazard and dust production (35 miles per hour except in areas of congestion, on bridges, and on pads, which should Yes See Measure 15.
be slower).
Birds Haze birds out of the blast area before blasting (if resident birds are present in winter). Yes See Measure 16.
Birds Minimize noise impacts between June 1 and July 15 when birds on nests would be unable to move away from the disturbance. Yes See Measure 16.
Birds Minimize air traffic during the nesting period when the movements of incubating birds are restricted, and the molting period when birds may be energetically No ROP F-1 sufficiently protects birds from air traffic.
stressed and sensitive to disturbance.
Birds Avoid routine use of helicopters during drilling and operations activities to minimize noise and impacts related to birds. No ROP F-1 sufficiently protects birds from air traffic.
Birds Consider revising traffic patterns, altitude, and location to minimize conflicts with molting geese. No There are no goose molting areas in NPR-A that would overlap with the selected project
Alternative and Module Delivery Option.
Birds Avoid preferred habitats, where possible. No Project facilities have been located to the extent possible to avoid preferred habitats of listed
spectacled and Steller’s eiders. Ice roads could be routed to avoid preferred habitats, but that
would place them in moist and shrub habitats where ice roads cause more damage to
vegetation. Because of the dispersion of preferred habitats with non-preferred habitats, it is
not feasible to avoid overflying preferred habitats. Flight altitude restrictions (1,500 feet
above ground level) reduce disturbance to nesting birds.
Birds Minimize barge and support vessel speed to reduce potential for bird strikes. Yes See Measure 15.
Birds Complete upgrades to the Kuparuk gravel road system involving wetland fill before or after the nesting season (June 1 through July 31), if possible. No The Kuparuk gravel road system is outside of NPR-A and not managed by BLM.
Terrestrial ROP E-6 describes requirements related to caribou ramps over pipelines or buried pipelines. The Project could designate specific locations for these, such as Yes See Measure 17.
Mammals northeast of the airstrip in Alternative B, or areas where caribou movements could be funneled or where roads and pipelines would be close together. The
decision to add a crossing ramp over a buried pipeline should consider potential negative effects of reduced access to the pipeline for oil spill detection and
response and thermokarst or changes in surface flow due to the resulting long-linear ditch that would fill with water.
Terrestrial Install game cameras to study the effectiveness of measures used to reduce vehicle traffic impacts, such as stopping traffic or caravanning. No This method of monitoring is expensive and labor-intensive and has not been shown to be
Mammals effective in this area, as cameras would capture thousands of pictures of tundra for every
picture of caribou and data typically yield results that are difficult to tie to definitive
conclusions.
Terrestrial Include the following in the vehicle use plan to minimize traffic impacts (plan is required as per ROP M-1): No NSB Rezoning Condition of Approval 3 already requires that a Vehicle Use Plan be
Mammals  Require vehicles to stop traffic when 25 or more caribou appear to be approaching the road. developed for the Willow project. The plan requires vehicles to stop when groups of 10 or
 Require vehicles to caravan or require periodic traffic closures when groups of caribou are near a road and the road has traffic rates of more than 15 more caribou are approaching the road. This is a reduction from 25 as required in the 2020
vehicles per hour. Caravanning has limited ability to lower calving displacement (Lawhead, Prichard et al. 2004), but it may increase crossing Willow ROD. The plan also incorporates seasonal speed limitations during caribou calving
success on roads with high traffic levels (more than 15 vehicles per hour) by providing periods without traffic to allow caribou to cross. It may be season and the fall migration season as well as other measures to limit traffic on roadways.
easier logistically to close the road for a specified number of hours a day (as determined by BLM) rather than caravanning. Spring, fall, and winter
would likely be the periods of greatest concern for caribou crossing Project roads.
Terrestrial Restrict Q400 traffic between Alpine and Willow at certain times of year to reduce impacts to caribou. Yes See Measure 18.
Mammals
Terrestrial Require the use of propylene glycol for deicing and for vehicle cooling systems, which is not toxic to wildlife. Yes See Measure 19. Note that propylene glycol would be used for deicing but cannot be used in
Mammals some vehicle cooling systems per manufacturer specifications. Potentially toxic chemicals
used by equipment fleets are managed according to EPA and ADEC requirements.
Subsistence and Inform employees who are North Slope residents of company subsistence leave policies and ensure that leave policies are flexible to account for annual No Lessee leave policies are outside of BLM’s jurisdiction.
Sociocultural variation in the timing and length of subsistence activities.
Systems
Subsistence and Employ subsistence representatives who receive daily communications on Project activities and report potential conflicts with subsistence users. Subsistence No ROP H-1 sufficiently meets the objective to prevent unreasonable conflicts between
Sociocultural representatives should be provided with clear communication protocols and training, be local and knowledgeable residents, and be included in field activities subsistence users and other activities.
Systems the community believes have a high potential of conflicting with subsistence uses (e.g., helicopter-based surveys).
Subsistence and In coordination with local organizations, such as the KSOP (required in CPAI design measure 68), ensure communications include the timing and location of No ROP H-1 sufficiently meets the objective to prevent unreasonable conflicts between
Sociocultural development activities such as air traffic, blasting, and other construction activities. subsistence users and other activities.
Systems
Subsistence and Identify areas with high drifted snow accumulation along pipelines after construction and implement a snow management program to clear drifts and create No Pipelines 7 feet and higher, as proposed for Willow, rarely (if ever) create drifts large
Sociocultural access points (i.e., openings) in areas where drifts accumulate for a long distance (e.g., quarter- and half-mile lengths) along pipelines. Consult with Nuiqsut enough to prevent movement.
Systems residents on an appropriate distance for cleared access areas as well as the depth of snowdrifts that impede travel under pipelines.
Subsistence and As part of the Subsistence Plan (required in ROP H-1) and as part of the Proponent’s notification and consultation with Alaska Native groups (ROP H-1), No ROP H-1 sufficiently meets the objective to prevent unreasonable conflicts between
Sociocultural provide equal opportunities for various local entities (e.g., KSOP, NVN, City of Nuiqsut, Kuukpik), in addition to knowledgeable subsistence users, to provide subsistence users and other activities.
Systems input.
Subsistence and Continue to consult with local subsistence users and community organizations regarding the appropriate design and location of subsistence boat ramps, Yes See Measure 21.
Sociocultural pullouts, and subsistence tundra access ramps. Consult with other operators regarding other boat ramp projects on the North Slope that may inform future
Systems designs.

Resource(s) Adopted
(Yes or No)
Subsistence and Participate in Conflict Avoidance Agreements with the Alaska Eskimo Whaling Commission to reduce potential impacts on bowhead whale hunting resulting No ROP H-1 sufficiently meets the objective to prevent unreasonable conflicts between
Sociocultural from barge and vessel traffic. subsistence users and other activities. BLM does not have the authority to require an
Systems applicant to hire locals.
Subsistence and Work with community organizations to establish measures to reduce impacts of vehicle traffic on subsistence activities, particularly during the Project’s No ROP H-1 sufficiently meets the objective to reduce impacts of vehicle traffic on subsistence
Sociocultural construction phase. activities.
Systems
Subsistence and Install traffic control signs (e.g., stop signs) to halt industry vehicle traffic at all subsistence access ramps to ensure that subsistence users can cross safely No Establishing an expectation in the minds of subsistence users that industrial size vehicles will
Sociocultural stop for them would create an extremely hazardous situation biased dangerously against the
Systems safety of the subsistence user.
Subsistence and Place development-free buffer around Native Allotment be at least 1 mile to ensure the viability of the allotment for subsistence use. Exceptions would be No Setbacks are already addressed at the plan level in the NPR-A Integrated Activity Plan.
Sociocultural made for allotment owners who agree to having development closer than 1 mile. Measure does not mitigate Project specific impacts.
Systems
Environmental Continue to use the KSOP to maintain meaningful engagement in the Project and identify continuing concerns and specific Project impacts. No ROP H-1 sufficiently meets the goal of maintaining meaningful engagement in the Project
Justice by the community and to identify continuing Project concerns.
Environmental Attend government to government meetings between NVN and BLM, as requested by NVN or BLM, to discuss issues and resolution strategies through Yes See Measure 22.
Justice construction and operations.
Public Health Limited health data are available for Nuiqsut. The best data available date from the NSB’s 2010 survey. Funding a collection of health information for Nuiqsut No Public health monitoring is the purview of the State of Alaska and NSB and would require
and studies of contaminant levels in local subsistence resources would provide better data for evaluation of potential health effects associated with oil field handling of sensitive information protected under Health Insurance Portability and
development and operation. Accountability Act.
Public Health Create a public health monitoring program at a regional level to track health indicators that are vulnerable to impacts from oil and gas activities. These No Public health monitoring is the purview of the State of Alaska and NSB and would require
indicators should focus on health outcomes and/or determinants of local concern that can be tied to oil and gas activity. Where possible, indicators should handling of sensitive information protected under Health Insurance Portability and
include threshold levels and specific actions should be developed for when thresholds are surpassed. The State should be responsible for the development and Accountability Act.
implementation of the monitoring program; however, the NSB and the Alaska Native Tribal Health Consortium should be consulted in the identification of
appropriate indicators, thresholds, and responsive actions.
Public Health Establish a Nuiqsut public health coordination group to conduct health education and engage the community in the public health monitoring program No Establishing a public health coordination group would be the proper role of the State of
described above. Alaska; it is beyond the expertise of BLM, which is not a public health agency.
Note: ADEC (Alaska Department of Environmental Conservation); ADNR (Alaska Department of Natural Resources); BLM (Bureau of Land Management); CPAI (ConocoPhillips Alaska, Inc.); EIS (Environmental Impact Statement); EPA (U.S. Environmental Protection Agency); HDD (horizontal directional
drilling); KSOP (Kuukpik Subsistence Oversight Panel); Kuukpik (Kuukpik Corporation); MTI (module transfer island); NMFS (National Marine Fisheries Service); NPR-A (National Petroleum Reserve in Alaska); NSB (North Slope Borough); NVN (Native Village of Nuiqsut); ROP (required operating
procedure); VSM (vertical support member); WSE (water surface elevation).
Table 4.2 Cooperating Agency Suggested Mitigation Measures for the Willow MDP Supplemental Environmental Impact Statement
Measures No. Affected Objective Standard/Requirement Mitigation Rationale For or Against Adoption
in the 2022 Resource(s) Adopted
Draft (Yes/No)
Supplemental
EIS
1 All Provide time between development Proposed projects that would have a gravel footprint exceeding 300 acres would be No This measure does not mitigate known project effects. Establishment of a mandatory pause in
projects to observe impacts and changes to limited to developing no more than 65% of the proposed project before instituting a development is arbitrary and could unnecessarily extend the duration of project impacts.
baseline conditions. Observations from minimum 2-year pause to observe project impacts (e.g., permafrost, hydrology, Monitoring of project impacts to resources including permafrost, hydrology, caribou, and
developed projects may result in additional caribou, subsistence). The authorized officer will be responsible for determining the subsistence is required under existing required operating procedures and lease stipulations within
NEPA review and analysis, changes to need for permit review based on the monitored findings. the NPR-A as well as NSB Rezone Mitigation Measures and Conditions of Approval. The BLM
proposed projects (including phases), may voluntarily conduct additional analysis of any project if it is determined that a change in
and/or new mitigation measures. conditions warrants reanalysis.
2 All Provide time before the construction of Drill site BT5 and the gravel roadway to BT5 will not be authorized for construction No The selected alternative, Alternative E, as modified, disapproves construction of BT5.
Project drill site BT5 is authorized to for three years after the construction of the Project's other three drill sites is complete.
observe overall project impacts and
changes to environmental baseline
conditions.
3 Socioeconomics; Provide Nuiqsut with a guaranteed The NPR-A Impact Mitigation Fund will direct a minimum of 15% of the grant No The BLM does not have the authority to direct grant funding allocations from the NPR-A Impact
Environmental minimum proportion of the impact funding to the City of Nuiqsut. This direct funding would not prevent Nuiqsut from Mitigation Fund. The NPR-A Impact Grant Program is managed by the Alaska State Department of
justice mitigation fund as the Nuiqsut is the applying for grants from the NPR-A Impact Mitigation Fund. Commerce, Community and Economic Development.
community most directly impacted by oil
and gas development.

Draft (Yes/No)
Supplemental
EIS
4 Socioeconomics; Provide additional resources to Nuiqsut to CPAI will provide Nuiqsut $250,000 for search and rescue equipment and operations No This measure does not mitigate known project effects. CPAI has voluntarily committed to engage
Public health support search and rescue efforts. With with the start of Project construction (i.e., gravel placement). CPAI will provide a with the Nuiqsut search and rescue group to identify opportunities for CPAI to support them with
expanded oil and gas development, many second $250,000 payment to Nuiqsut for additional search and rescue equipment equipment needs or equipment staging. CPAI will continue to support the Nuiqsut Community
Nuiqsut residents travel further from the following commissioning of the Willow processing facility. Development Foundation which supports the City of Nuiqsut in obtaining and managing grants for
village to pursue subsistence opportunities. community needs, such as search and rescue.
This expanded range strains the current
search and rescue program in the
community.
5 Caribou; Reduce the amount of equipment traveling Install caribou monitoring stations that use real time caribou GPS telemetry data (i.e., No It is not possible to obtain real time location data from GPS telemetry collars due to satellite upload
Subsistence on Project roads at specific times to reduce caribou collars) and manage road use for successful caribou passage. The applicant times which create an average lag of between 1 and 4 days between data upload and database
impacts to caribou and subsistence users. and BLM will consult with the NSB wildlife department and ADF&G caribou experts download. As such, it is not reasonable to rely upon GPS collar data alone to establish traffic
to identify the minimum percentage of the Teshekpuk Caribou Herd that should have restrictions.
active GPS telemetry collars and the caribou density and distance from Project roads
NSB Rezoning Required Measure 13 requires CPAI to assist ADF&G or the NSB Division of
that will initiate traffic restrictions.
Wildlife Management in the collection of GPS telemetry data in support of analyzing the
distribution and movements around the Willow Project area to assess and reduce impacts from
Project activities. Implementation of this measure and the Vehicle Use Plan required under NSB
Rezoning Condition of Approval 3 sufficiently meets the objective to reduce the amount of
equipment traveling on Project roads to reduce impacts to caribou and subsistence users.
6 Caribou; Reduce impacts to calving caribou Outdoor construction activity (e.g., gravel working, building fabrication) will be halted No Stopping activity after caribou are observed within 1 mile would not substantially minimize
Subsistence (approximately May 20 through June 20). during caribou calving season when calving caribou are within 1 mile of the activity. impacts to calving caribou. Caribou will generally be at lower than expected densities within
Drilling and operations activity will be minimized at drill site pads during caribou approximately 4 kilometers (2.5 miles) of roads during calving so few calving caribou would be
calving season to the extent that is safely practicable; new activities (e.g., initiating expected within 1 mile of active roads unless activity is already halted.
drilling for a new well, hydraulic fracturing) will not be initiated at drill sites during
Requirements to limit or prohibit activities during caribou calving season were contemplated and
this time.
addressed in the 2020 NPR-A IAP/EIS under ROP K-9, the provisions of which apply to the
TLCHA. The geographic boundary of the TLCHA was established in the 2022 NPR-A IAP/ROD.
No Willow project activities would occur within the TLCHA. There are no impacts unique to this
project that warrant expansion of the geographic scope of ROP K-9.
7 Air quality; Public Collect air quality monitoring data in the Install air quality monitoring stations at a predominantly down-wind location on a Yes See Measure 23.
health; immediate area of development, between gravel pad used to directly support drilling or operations (e.g., drill site pad, processing
Environmental Nuiqsut and the Willow Project, to confirm facility pad). One air monitoring station will be required for every five drill site pads
justice the Project is operating at anticipated or single processing facility, per development project. This data will be collected and
emissions levels (i.e., as modeled) and be made publicly available in real time through the North Slope Science Initiative
provide a record of regulatory emissions website.
violations.
8 Caribou Limit overall activity or minimize air ROP F-1 requires the use of an Aircraft Use Plan. The plan will include the following: Yes See Measure 18.
traffic at specific times to reduce impacts to • Minimize Q400 traffic between Alpine and Willow during calving (May 20 to
caribou. June 20) to reduce impacts to caribou. Q400 traffic between Willow and Kuparuk
or Deadhorse is necessary and would be allowed.
• Plans to minimize the disturbance to calving caribou (description of areas avoided,
how flight numbers were minimized, and that low altitude flights were avoided or
limited).
9 Subsistence Maintain subsistence ramp access, Materials and equipment shall not be staged on gravel road pullouts or in such a way Yes See Measure 21.
including pullout surface area, free of as to block subsistence ramps or the roadway view for subsistence ramp users. Safe
obstructions, including equipment and access to subsistence ramps will be maintained. Operators will incorporate staff
material storage. training on the importance of maintaining clear and safe areas around pullouts and
subsistence ramps into their orientation and safety programs. Operators will install
signs at roadway pullouts stating, “Equipment and Materials Shall Not be Staged
Here”.

Draft (Yes/No)
Supplemental
EIS
10 Water resources; Dispose all Project waste properly and in a Waste management plans shall specify the intervals for total site cleanup at areas of No ROP A-2 sufficiently meets the objective to dispose of all Project waste properly and in a timely
Wetlands and timely manner. activity. Cleanup intervals will not exceed 72 hours during periods of activity, manner. During construction and operations activities clean up intervals typically do not exceed 24
vegetation; Fish; including on Project pads. hours.
Birds; Terrestrial
mammals; Marine
mammals;
Subsistence
11 Birds Further reduce impacts to nesting Yellow- In areas where roads cross through Yellow-billed loon nesting buffers, maximum Yes See Measure 15. Note that the speed limit as adopted is 35 mph year-round on gravel roads, not just
billed loons from vehicle traffic. vehicle speeds will be restricted to 25 mph within the buffer zone during the nesting during nesting season. While it is possible that reducing the speed limit to 25 mph would further
season (approximately June 1 through July 31). These speed limits will be prominently reduce the risk of vehicle/bird collisions, such occurrences would be very rare.
signed during this period.
12 Climate change To minimize or avoid environmental harms A NEPA adequacy review will be completed if the barrels per day gross annual No This measure would provide no additional reduction of known Project effects. The requirement for
caused by greenhouse gas emissions and average is greater than 10% of the original barrels per day production target (disclosed compliance with the National Environmental Policy Act arises when there is a proposal for a major
ensure NEPA adequacy over the life of the in the development’s most recent NEPA document) over a two-year period; or when Federal action. The suggested points of re-analysis are not tied to specific BLM action; therefore,
Project. Analysis by the EPA indicates that the cumulative recovered reserves are greater than 10% of the original estimated no additional NEPA would be required by regulation. However, BLM may voluntarily conduct
with technological advances and new data recoverable reserves (disclosed in the development’s most recent NEPA document). additional analysis if it is determined that a change in conditions warrants reanalysis.
provided by infield drilling following a
development and production
environmental impact statements, more
petroleum hydrocarbons are often extracted
from the target reservoir than originally
estimated. This results in more greenhouse
gas emissions produced than estimated or
disclosed to the public.
13 Water resources; Protect surface waters in the Project area The Project will include an adaptive management plan "that provides detail regarding No Measure 6 as adopted in this ROD ensures that culverts, bridges, and pipeline stream crossings are
Wetlands and through monitoring and mitigation. how any unanticipated surface water flow blockages would be identified and corrected designed in such a manner as to reduce unanticipated surface water flow blockages. Special
vegetation; Fish as quickly as possible, to avoid lasting environmental impacts" for monitoring and Condition 11 of the USACE Section 404 permit requires that the natural drainage patterns be
mitigation of potential surface water flow impacts throughout the project area. maintained along access roads and pads, and if there is evidence of altered hydrology (such as
excessive ponding, drying, channelization), CPAI is required to restore hydrology to
preconstruction conditions. Adherence to this measure and condition sufficiently meets the
objective.
14 Water resources Protect and minimize impacts to surface The Project will include an adaptive management plan for the Colville River crossing Yes See Measure 10.
waters at Ocean Point and across the activity at Ocean Point.
Project area.
15 Water resources; Minimize floodplain impacts where gravel The Project will prepare an adaptive management plan to address potential floodplain No Measure 6 as adopted in this ROD ensures that culverts, bridges, and pipeline stream crossings are
Wetlands and roads, pads, or boat ramps may block or impacts where gravel roads, pads, or boat ramps may block or restrict the flow of designed in such a manner as to reduce unanticipated surface water flow blockages. Special
vegetation; Fish water during spring breakup. The adaptive management plan will provide methods for
restrict the flow of surface waters during Condition 11 of the USACE Section-404 permit requires that the natural drainage patterns be
spring breakup through timely detection detecting and correcting unanticipated blockages before they lead to further maintained along access roads and pads, and if there is evidence of altered hydrology (such as
and corrective action. environmental degradation. The adaptive management plan will address the potential excessive ponding, drying, channelization), CPAI is required to restore hydrology to
for spring breakup surface waters to: preconstruction conditions. Adherence to this measure and condition sufficiently meets the
• Increase the depth and duration of water impoundment objective.
• Increase thermokarsting
• Cause a change in flow direction
• Cause channel instability or a change in alignment
• Result in erosion of the tundra or a stream channel
• Result in the deposition of sediment on the tundra or in a stream channel
16 Water resources; Minimize impacts to the water levels of CPAI will collect stage monitoring data for Willow Creek 3 and Lake M0015 during No The selected Alternative does not include construction of a constructed freshwater reservoir.
Wetlands and Willow Creek 3 and Lake M0015 resulting ice-free periods for three consecutive years prior to the start of construction of the
vegetation; Fish from the construction of the constructed constructed freshwater reservoir (under Alternatives B, C, and D). This information
freshwater reservoir. will be used to ensure adequate water levels are maintained during the filling and
operations of the constructed freshwater reservoir.

Draft (Yes/No)
Supplemental
EIS
17 Climate change; Minimize the potential impacts of thawing CPAI will prepare an adaptive management plan that will be responsive to climate No Monitoring for thawing and thermokarst impacts to project infrastructure is a requirement of
Permafrost; Water and thermokarst from climate change on change by monitoring and mitigating potential thawing and thermokarst impacts on all CPAI’s road maintenance approach. In addition to CPAI monitoring obligations, BLM maintains
resources; Project structures, including roads, pads, Project structures including roads, pads, and the constructed freshwater reservoir. its own soil/snow monitoring network within NPR-A which is used to consistently monitor
Wetlands and and the constructed freshwater reservoir to conditions for the duration of the winter development season. BLM releases a weekly, publicly
vegetation protect the TLSA. viewable, report with soil temperature and snow depth data which is shared with industry, other
agencies, and the public. BLM also conducts annual, winter and summer, inspections of ROWs
permitted in NPR-A with a heightened emphasis placed on winter road construction and observable
vegetative recovery. Industry also conducts its own geotechnical analysis for new development
proposals. These analyses allow for identification of site-specific issues such as thaw unstable soils
and are used for both routing and engineering design. Implementation of these efforts sufficiently
meets the objective.
18 Public health; Collect health baseline data for a Fund the collection of baseline health information on Nuiqsut residents and a No Public health monitoring is the purview of the State of Alaska and NSB. ROP A-11 requires
Environmental Community Health Study what will inform Community Health Study that studies contaminant levels in local subsistence baseline studies and monitoring of contaminants in local subsistence foods such that the objective is
justice evaluation of potential health effects resources. The study shall include a section on potential trends that may have occurred sufficiently met.
associated with oil and gas developments. in local health during the Covid-19 activity slowdown in 2020.
19 Air quality; Reduce the concentration and/or intensity CPAI will prepare a coordination plan between the Kuparuk, Alpine, and Willow No In accordance with Design Measure 121, flaring for the Willow project is conducted to support
Climate change; of flaring near Nuiqsut. developments to minimize the use flaring across all three developments and to reduce process safety only (no flaring is to be conducted for production). As such, it would not be feasible
Public health; the incidences of multiple facilities flaring simultaneously. When simultaneous flaring for the BLM to set arbitrary limits on flaring timing, as that would present a safety risk and be
Visual resources must occur, the length of flare overlap shall be minimized to the greatest extent completely unworkable. Flaring occurrences for wells within the NPR-A are monitored by the
possible. BLM. Flaring is regulated through the Notice to Lessees (NTL-3) along with reporting
requirements for undesirable events which includes venting and flaring and the cause of release.
BLM reviews and evaluates these reports to ensure no undue discharge is occurring. Note that
Kuparuk is not located within the NPR-A and is therefore outside of the BLM 's jurisdiction.
20 Environmental Improve local understanding and Fund traditional and western scientific education programs in Nuiqsut schools to help No Consistent with Design Measure 74, CPAI will continue its internship program (CareerQuest) to
justice knowledge of traditional and scientific inform and improve the community's understanding of the oil and gas industry introduce Nuiqsut high school students to jobs and careers in the oil field and in their community.
principles related to the oil and gas industry development and its associated impacts. As such, implementation of Design Measure 74 sufficiently meets the objective.
for school age children in Nuiqsut.
21 Fish; Birds; Utilize local knowledge by including Include local advisors (e.g., elders, tribal council members, hunters, NSB wildlife No ROP H-1 and Design Measures 68 and 69 require continued consultation with local communities
Terrestrial community members (e.g., elders, tribal experts) as team members when conducting studies, identifying historic sites, and concerning subsistence use. NSB Rezoning Required Mitigation Measure 38 requires engagement
Mammals; Marine council members, hunters, NSB wildlife completing Project planning. of the NSB Iñupiat History, Language and Culture in the identification of historic sites. NSB
Mammals; experts) when conducting studies and Rezoning Required Mitigation Measure 3 requires that CPAI consult with NSB, NVN, Kuukpik,
Subsistence; Project planning. and KSOP at least annually concerning ongoing project activities, plans, and impacts.
Environmental Implementation of these measures sufficiently meets the objective to utilize local knowledge when
justice; Cultural conducting studies and Project planning.
resources
22 Fish; Birds; Provide the community with information Fund an NSB wildlife biologist position stationed in Nuiqsut to help the community No NSB Rezoning Required Measure 37 requires that CPAI hire a year-round subsistence
Terrestrial on the health of local subsistence and NSB monitor wildlife health and provide the community information on the safety representative. This, in combination with the requirements of ROP A-11 and ROP H-1 sufficiently
Mammals; Marine resources. of consuming subsistence resources. meets the objective.
Mammals;
Subsistence;
Environmental
justice;

Draft (Yes/No)
Supplemental
EIS
23 Subsistence; Improve the design and deployment of Develop an adaptive management plan for subsistence access ramps that considers Yes See Measure 21. Note that selected Alternative will include five vehicle turnouts/ subsistence
Public health subsistence access ramps so they are safe community input for improvements to subsistence ramp design and to address ramps for approximately 25.8 miles of new gravel road. The occurrence of these ramps may not
and effective for community members. modifications of existing subsistence ramps. New subsistence ramps will be placed at necessarily be one within every three miles due to limitations of geography or sensitive surface
a minimum of 1 ramp for every 3 miles of new gravel road. values.
CPAI will meet with the community of Nuiqsut to establish subsistence ramp design
parameters to ensure the designs are adequate for users. Design parameters will
include a minimum length “landing ramp” at the top that is level and long enough to
accommodate snow machines pulling sleds without sleds having to enter the
associated pullout or adjacent road. The design parameters will set a maximum grade
of the ramps.
The subsistence ramp pullouts will be signed that materials and equipment are not to
be stored at pullouts. Warning signs will be placed on the adjacent roadway
approaching the subsistence ramp/pullout to warn drivers of the potential for vehicles
(e.g., snowmachines, all-terrain vehicles) crossing the road.
Subsistence ramp locations will be made available to local search and rescue groups
(e.g., Nuiqsut, NSB) as GPS coordinates and on published maps.
24 Gravel Support the local community's needs for Provide Nuiqsut gravel to support road maintenance, specifically the subsistence No This measure does not mitigate known project effects. Consistent with the provisions of 43 CFR
gravel infrastructure maintenance. access road. 3600, the BLM cannot compel the holder of a mineral sales contract to provide gravel resources to
users other than the contract holder.
25 Air quality; Fish; Collect additional air pollutant data in Expand the air monitoring capabilities in Nuiqsut to include monitoring for hazardous Yes See Measure 23.
Birds; Terrestrial Nuiqsut and make the data available to the air pollutants, volatile organic compounds, and polycyclic aromatic hydrocarbons. The
mammals; Marine public. measured concentrations will be made available in near real time for the community
mammals; and the public at large.
Subsistence;
Public health;
Environmental
health
26 Terrestrial Reduce caribou deflection. Aboveground pipelines shall have a nonreflective finish. No Design Measure 59 requires the use of non-reflective finishes on pipelines.
mammals;
Subsistence
27 Wetlands and Test local subsistence resources for Provide periodic testing of consumable subsistence resources for contamination. No ROP A-11 sufficiently meets this objective.
vegetation; Fish; contamination. Testing frequency and the number of samples tested per testing interval will be
Birds; Terrestrial determined in consultation with the community of Nuiqsut.
mammals; Marine
mammals;
Subsistence;
Public health;
Environmental
health
28 Air quality; Public Provide independent oversight and CPAI shall fund the Nuiqsut air quality monitoring station. A third-party contractor No CPAI currently owns and operates the air quality monitoring station in Nuiqsut. Lessee hiring and
health; management to the air quality monitoring will be identified to operate and maintain the station. The third-party contractor will staffing directives are outside of the BLM's jurisdiction.
Environmental station in Nuiqsut. develop a training program open to Nuiqsut residents for operating and maintaining
justice the monitoring station, with appropriate technical oversight completed by the
contractor.
29 Subsistence Provide local subsistence oversight of all A subsistence representative shall be present whenever field activity is occurring, No NSB Rezoning Required Measure 37 requires that CPAI hire a year-round subsistence
field activity being conducted in support of including having representatives scheduled to cover day and night work shifts. representative. Lessee staffing directives are outside of the BLM's jurisdiction.
the Project. Subsistence representatives are to be included in all field activities conducted in
support of the Project.

Draft (Yes/No)
Supplemental
EIS
30 Air quality; Water Actively monitor for pollution indicators in Develop an ongoing contamination study program (e.g., snow sampling, fish No ROP A-11 sufficiently meets this objective. Establishing thresholds for contamination reporting is
resources; the environment for the duration of the sampling) and adaptive management plan to address found contamination. Any outside of the jurisdiction of the BLM as it is not a public health agency.
Wetlands and Project and modify Project activities as contamination found in excess of State or EPA levels will be reported to ADEC within
vegetation; Fish; needed to address found contamination. 72 hours of being determined.
Birds; Terrestrial
mammals; Marine
mammals;
Subsistence;
Public health;
Environmental
justice
31 Air quality; Water Monitor for and minimize impacts from Monitor water quality, permafrost, and vegetation near sites where hydraulic No ROPs A-2, A-3 and A-4 sufficiently meet the objective by ensuring appropriate measures are in
resources; hydraulic fracturing or underground fracturing or deep well injection (i.e., underground injection control wells) are place to prevent contamination and requiring appropriate response to occurrences of contamination.
Wetlands and injection control disposal well operation. occurring for potential contamination or unanticipated impacts. Develop an adaptive
vegetation; Fish; management plan that outlines how impacts would be analyzed and potentially
Birds; Terrestrial addressed.
mammals; Marine
mammals;
Subsistence;
Public health;
Environmental
justice
32 Wetlands and Protect vegetation along ice road routes. Monitor vegetation along ice road footprints for vegetation damage and compression No Existing requirements under ROP C-2 and NSB Rezone Required Measure 46 and 48 ensure that
vegetation of soil and vegetation. Because ADNR monitors only tussock tundra and soil ice roads shall be designed to minimize impacts to vegetation. The NSB also requires monitoring of
compaction, this measure focuses on non-tussock wetlands (including patterned ice road impacts such that the objective is sufficiently met.
ground) with a Cowardin water regime class of Temporarily Flooded, Saturated, or
Seasonally Flooded Ground by vegetation type (total live cover of graminoid, shrub,
forb, moss). Additionally, the percentage of bare soil would be monitored with control
points and points within ice road footprints to determine changes.
33 Water resources; Provide the Nuiqsut community with a The community of Nuiqsut shall be involved in the development of studies in the No ROP H-1 and Design Measures 68 and 69 require continued consultation with local communities
Wetlands and level of control and oversight on baseline Project area, from study design to implementation. CPAI shall present planned studies concerning subsistence use. NSB Rezoning Required Mitigation Measure 38 requires engagement
vegetation; Fish; studies to Nuiqsut. (e.g., study requirements, methodology, timing) to the community and incorporate of the NSB Iñupiat History, Language and Culture in the identification of historic sites. NSB
Birds; Terrestrial feedback as practicable. CPAI will provide regular updates to the community about Rezoning Required Mitigation Measures 3 requires that CPAI consult with NSB, NVN, Kuukpik,
mammals; Marine ongoing studies and study planning. and KSOP at least annually concerning ongoing project activities, plans, and impacts; per NSB
mammals; Rezone Required Measure 8 CPAI will consult with KSOP on all study designs prior to submittal
Subsistence; to the NSB. NSB Rezone Required Measure 12 requires that to the extent practicable, CPAI will
Environmental involve students from Nuiqsut or other local communities in studies. Implementation of these
Justice measures sufficiently meets the objective. Environmental studies are published online at
https://northslopescience.org/ and updates on ongoing studies are provided on at least an annual
basis.
34 Subsistence New bridges will not interfere with CPAI shall consult with Nuiqsut on the design of proposed Project bridges to ensure Yes See Measure 21. Note that all Willow bridges have been designed to facilitate boater passage.
subsistence activity. they provide adequate clearances and safe passage for boaters traveling along
waterways.
35 Socioeconomics Protect oilfield workers from retaliation for CPAI shall institute whistleblower protections for CPAI employees or their No This measure is not within the proper jurisdiction of BLM to enforce and would duplicate
reporting on-the-job issues. contractors who report violations to company policy, regulatory requirements, or state requirements of existing law.
and local laws.
36 All Provide adequate agency (State of Alaska BLM shall coordinate with the State of Alaska and the NSB to provide an adequate No This measure does not mitigate known project effects. CPAI is required to provide reasonable
and the NSB) oversight of Project number of inspectors on site during construction and operations of the Project to access for all BLM inspection needs.
construction and operations to ensure ensure the project is in compliance with its permits. CPAI shall provide site access and
permit compliance. accommodations to the required inspection staff.
37 Subsistence Identify important inter-community CPAI shall conduct at least two multi-village workshops during project development No ROPs E-1, H-1 in combination with implementation of Design Measures 68 and 69 sufficiently
subsistence areas. to identify important inter-community subsistence areas. The communities included meet the objective.
for the Project are at a minimum: Nuiqsut, Utqiaġvik, Anaktuvuk Pass, and Atqasuk.

Draft (Yes/No)
Supplemental
EIS
38 Fish; Terrestrial Determine potential impacts mine site Develop and conduct a study to monitor for and determine potential impacts that may No ROP H-1 and NSB Rezone Required Measures 13 and 21 requires monitoring studies of project
mammals; blasting has on fish returns and caribou occur to fish returns and caribou migration from mine site blasting. impacts to caribou and fish within the Willow area. Implementation of these measures sufficiently
Subsistence migration. meets the objective.
39 Water resources; Determine if contaminants potentially Institute a monitoring program for drill site BT2 to determine if contamination No ROPs A-2, A-3 and A-4 sufficiently meet the objective by ensuring appropriate measures are in
Wetlands and migrate off the drill site BT2 North pad. migrates off the gravel pad. Monitoring shall include water, snow, soil, and vegetation place to prevent contamination and requiring appropriate response to occurrences of contamination.
vegetation; Fish; sampling. Any contamination found in excess of State or EPA levels will be reported These ROPs are required for all Project activities. All instances of reportable spills (required by 40
Birds; Terrestrial to ADEC within 72 hours of being determined. CFR 300.125 and Alaska Administrative Code 75.300) must be made to the BLM no later than 24
mammals; Marine hours after the occurrence. Additionally, water quality monitoring is the purview of the ADEC.
mammals;
Subsistence
40 Subsistence; Nuiqsut residents must rely on imported Imported foods are frequently stored improperly and are damaged or ruined prior to No This measure does not mitigate known Project effects. The condition of food storage at airports is
Public health foods to a greater extent when subsistence arrival in Nuiqsut. CPAI shall pay to construct food storage facilities at airports in outside of the BLM's jurisdiction.
resources are negatively impacted by oil Deadhorse and Utqiaġvik to protect perishable goods from precipitation, freezing,
and gas development. Protect imported spoiling, and wildlife.
food supplies during transit through
Utqiaġvik and Deadhorse to Nuiqsut.
41 Socioeconomics; Provide laboratory testing in Nuiqsut for Construct and operate an environmental testing laboratory in Nuiqsut. No This measure does not mitigate known project effects. Most samples are currently processed in at a
Environmental standard testing protocols to avoid having lab in Prudhoe Bay with samples requiring more sophisticated testing technology sent to
justice to send samples for testing to Utqiaġvik, Anchorage or Fairbanks. It is not reasonable or necessary to process all environmental tests in
Fairbanks, or Anchorage. Nuiqsut.
42 Terrestrial Minimize the deflection and disruption of Restrict noise (e.g., limit drilling, limit construction activity) when caribou are present No A white noise generator would be additive to project sounds and would increase overall project
mammals; caribou migratory patterns. during the calving and migration periods. When noise is unavoidable, avoid abrupt noise impacts on all resources, including caribou, and communities. Use of a white noise generator
Subsistence sounds. A steady drone of noise is easier for caribou to acclimate to, so consider to mask louder noise impacts to wildlife has not been tested.
adding a white noise generator if necessary to lessen abrupt sounds.
43 Terrestrial Minimize the deflection and disruption of Limit the overall activity, including outdoor foot traffic, and minimize air traffic at Yes See Measure 18 (air traffic). Vehicle traffic is minimized in accordance with the Vehicle Use Plan
mammals; caribou migratory patterns. specific times to reduce impacts to caribou (especially during calving and migration as required by NSB Rezoning Condition of Approval 3. At all times, harassment of caribou using
Subsistence periods). vehicles is prohibited under ROP M-1 and consistent with CPAI policy. Impacts to caribou from
foot traffic associated with project activities is expected to be minimal; therefore, no specific
measure to minimize foot traffic is needed.
44 Terrestrial Minimize the deflection and disruption of Minimize visual impacts by fencing or otherwise camouflaging or screening pads and No The use of fencing/ screening around project infrastructure is not practicable for the following
mammals; caribou migratory patterns. areas that have the most activity and movement. Caribou are more likely to turn away reasons:
Subsistence from movement than from structures perceived as stationary objects. Caribou also • Size of pads would need to increase to account for screening thereby increasing impacts to
react more strongly and habituate less readily to foot traffic than to vehicle traffic tundra and surface waters.
• Screening would hamper moving equipment.
• Screening would create snow drifting and hinder snow removal.
• The Arctic Coastal Plain is very flat and structures are tall so screening would need to be on top
of the pads and be very tall to be effective.
• The Arctic Coastal Plain has high winds so screening would require significant structural
elements.
45 Terrestrial Minimize the deflection and disruption of Protect hunting success versus biological success by: Yes See Measure 17 (caribou crossing ramps) in support of requirements under ROP E-7.
mammals; caribou migratory patterns. • Reducing the number of animals required to halt traffic ("let the lead caribou
The Vehicle Use Plan required by NSB Rezoning Condition of Approval 3 requires that vehicles
Subsistence cross").
will stop when groups of 10 or more caribou are approaching the road. This is a reduction from 25
• Limiting traffic during the fall hunting period (approximately September 15 as required in the 2020 Willow ROD. The plan also incorporates seasonal speed limitations during
through October 15) and incorporate local recommendations for the timeframe. caribou calving season and the fall migration season.
• Following the Red Dog Mine model for caribou crossings.
• Use recommendations from the subsistence committee. ROP H-1 sufficiently meets the need to consult with local subsistence users on best practices and
• Stopping traffic as soon as caribou are sighted or when caribou are a half mile or recommendations for minimizing traffic during hunting season.
less from the road.
• Incorporate crossing ramps, 7-foot tunnels/overpasses, and/or visual windows into
road design when possible.
46 Terrestrial Minimize the deflection and disruption of Buffer the Teshekpuk Caribou Habitat area by 5 to 6 kilometers (3.1 to 3.7 miles) to No The geographic boundary of the TLCHA was established in the 2022 NPR-A IAP/ROD. No
mammals; caribou migratory patterns. account for the avoidance response of calving caribou to infrastructure. Willow Project activities would occur within the TLCHA. There are no impacts unique to this
Subsistence Project that warrant expansion of the geographic scope of ROP K-9.
Draft (Yes/No)
Supplemental
EIS
47 Terrestrial Minimize deflection and disruption of Use convoys and/or checkpoints to moderate traffic flow and to consolidate traffic in No The Vehicle Use Plan required by NSB Rezoning Condition of Approval 3 incorporates measures
mammals; caribou migratory patterns. space and time. to consolidate traffic in space and time that sufficiently meet the objective.
Subsistence
48 Terrestrial Minimize the deflection and disruption of Employ caribou monitoring personnel to maintain awareness of presence and No NSB Rezoning Required Measure 37 requires that CPAI hire a year-round subsistence
mammals; caribou migratory patterns through movements of caribou. representative.
Subsistence monitoring and awareness.
49 Terrestrial Minimize the deflection and disruption of Off-pad activities shall be suspended from May 20 through June 20, unless approved No Similar requirements were contemplated and addressed in the 2020 NPR-A IAP/EIS under ROP K-
mammals; caribou migratory patterns through by the authorized officer. The intent of this requirement is to restrict activities that 9, the provisions of which apply to the TLCHA. The geographic boundary of the TLCHA was
Subsistence suspension of off-pad activities at critical would disturb caribou during calving. established in the 2022 NPR-A IAP/ROD. No Willow Project activities would occur within the
times. TLCHA. There are no impacts unique to this Project that warrant expansion of the geographic
The permittee shall submit a stop-work plan that considers this, and other mitigation
scope of ROP K-9.
related to caribou early arrival. The intent of this latter requirement is to provide
flexibility to adapt to changing climate conditions that may occur over the life of the
Project.
50 Terrestrial Minimize the deflection and disruption of The following ground traffic restrictions shall apply to permanent oil and gas-related No Similar requirements were contemplated and addressed in the 2020 NPR-A IAP/EIS under ROP K-
mammals; caribou migratory patterns through ground roads: 9, the provisions of which apply to the TLCHA. The geographic boundary of the TLCHA was
Subsistence traffic restrictions on permanent oil and • From May 20 through August 20, traffic speed shall not exceed 15 mph when established in the 2022 NPR-A IAP/ROD. No Willow Project activities would occur within the
gas-related roads. caribou are within 0.5 mile of the road. Additional strategies may include limiting TLCHA. There are no impacts unique to this Project that warrant expansion of the geographic
trips, using convoys, using different vehicle types, stockpiling equipment and scope of ROP K-9.
materials, etc. to the extent practicable. The permittee shall submit with the
development proposal a vehicle use plan that considers these and other mitigation
measures.
• The permittee shall observe caribou movement from May 20 through August 20,
or earlier if caribou are present prior to May 20. Based on these observations,
traffic would be stopped:
o Temporarily to allow a crossing by 10 or more caribou. The permittee shall
submit with the development proposal a vehicle use plan that considers
these and other mitigation measures.
o By direction of the authorized officer, traffic may be stopped through the
Project area for a limited amount of time, and only if necessary to prevent
displacement of calving caribou. Such closures will not be undertaken
without first consulting with permittees to assess operational impacts on
permitted activities
51 Terrestrial Minimize the deflection and disruption of ROP F-1 requires the use of an Aircraft Use Plan. The plan will include the following: Yes See Measure 18.
mammals; caribou migratory patterns through air • Minimize Q400 traffic between Alpine and Willow during calving (May 20 to
Subsistence traffic restrictions. June 20) to reduce impacts to caribou. Q400 traffic between Willow and Kuparuk
or Deadhorse is necessary and would be allowed.
• Plans to minimize the disturbance to calving caribou (e.g., description of areas
avoided, how flight numbers were minimized, and that low altitude flights were
avoided or limited).
52 Subsistence Reduce the impacts to subsistence users Provide household level vouchers for fuel (not fixed dollar value) to support No NSB Rezoning Condition of Approval 6 requires that during the construction period of the Willow
resulting from increased travel subsistence activities on a quarter-annual basis. Project (prior to start-up of the central processing facility), if requested by the NSB Subsistence
requirements for subsistence users. Mitigation Committee, in addition to the existing contributions, CPAI will provide an annual air
charter for a group of Nuiqsut hunters and their gear to support caribou subsistence activities. In
addition, it requires CPAI to develop a Good Neighbor Policy on caribou in consultation with the
community of Nuiqsut and the NSB Wildlife and Planning Departments. The Good Neighbor
Policy will include support to transport Nuiqsut caribou subsistence hunters and their gear to and
from areas where caribou are available if it is determined that the Willow Project has significantly
impacted the ability of the hunters to harvest caribou based on criteria in the Good Neighbor Policy.
Implementation of these requirements sufficiently meets the objective in a manner inclusive of
community input and consultation.

Draft (Yes/No)
Supplemental
EIS
53 Public health Provide a funding source to support Provide funding to support the Nuiqsut healthcare clinic so that treatment options No This measure does not mitigate known project effects. Public health initiatives would be the proper
Nuiqsut healthcare needs. available in the clinic can address the most frequent concerns (e.g., asthma). role of the State of Alaska and NSB; it is beyond the expertise of the BLM, which is not a public
health agency.
54 Public health Provide a funding source for a professional Provide funding to the City of Nuiqsut to contract with a third-party professional No This measure does not mitigate known project effects. Public health initiatives would be the proper
third-party contractor to design and organization or consultant to develop and administer a human health study. The study role of the State of Alaska and NSB; it is beyond the expertise of the BLM, which is not a public
administer a human health study. shall consider unique aspects to life on the North Slope, including the consumption of health agency.
subsistence food sources.
55 Water quality; Provide BLM with ready access to CPAI’s Develop a road use agreement between CPAI and BLM that provides BLM unfettered No This measure does not mitigate known project effects. CPAI is required by law to provide access to
Terrestrial North Slope roads (e.g., Kuparuk, Alpine, access of project gravel and ice roads, except when safety may be jeopardized by road the BLM for inspections and monitoring.
mammals; Greater Mooses Tooth, Willow). conditions or activity.
Subsistence
56 Terrestrial Continue the long-term caribou monitoring Continue to fund the long-term caribou monitoring project in and near Nuiqsut No NSB Rezoning Required Measure 13 requires that CPAI continue to fund caribou monitoring
mammals; project in and near Nuiqsut through the life through the life of the Willow Project. studies around the Willow Project area.
Subsistence of the Willow Project to provide better
understanding of the effects of North Slope
oil and gas development on caribou.
57 Terrestrial Provide funding for a caribou collaring Provide a funding mechanism to support ongoing caribou collar studies through No NSB Rezoning Required Measure 13 requires that CPAI continue to fund caribou monitoring
mammals; study within the Willow Project area. construction of the Willow Project and five years of operations only activity to provide studies, to include caribou collar studies, around the Willow Project area.
Subsistence a better understanding of caribou responses to increased oil and gas development.
58 Sociocultural Support the development of a cultural Provide funding to help design and develop a cultural center in Nuiqsut for the No This measure does not mitigate known project effects. Such a project would be more properly
systems center in Nuiqsut. community’s use. supported through NPR-A Impact Mitigation Fund grants.
59 Terrestrial Provide funding for a caribou movement Provide a funding mechanism to support ongoing Teshekpuk Caribou Herd studies in No NSB Rezoning Required Measure 13 requires that CPAI continue to fund caribou monitoring
mammals; study in the Alpine and Greater Mooses the Alpine and Greater Mooses Tooth project areas with a focus on how caribou studies around the Willow Project area.
Subsistence Tooth project areas. respond to roads and vehicle traffic.
60 Birds Prevent collisions by birds with overhead Add to ROP E-15: Communication towers should be monopoles without guy wires Yes See Measure 15.
power lines and guy wires during mating, that could be a collision hazard for birds.
inclement weather (e.g., fog), and
migration
61 Birds Use white strobe lights instead of solid, or Add to ROP E-8: For tower structures exceeding 200 feet in height with FAA required Yes See Measure 15.
pulsating (beacon) red lights to reduce lighting, use white (preferable) or red strobe lights. The strobes should be set at the
attracting night-migrating birds to tower minimum number of flashes per minute allowable by the FAA. The use of solid red or
structures exceeding 200 feet in height pulsating red warning lights at night should be avoided, if possible.
with required FAA lighting
62 Birds Protect birds during nesting season Construction/placement of gravel for roads and pads should occur in winter to avoid No Project schedule is already designed such that gravel placement activities are to occur during winter
damage to nesting birds, eggs, and hatchlings and adjacent tundra habitats. No gravel months only. Measure 16 in this ROD requires that, to the greatest extent practicable, construction
placement or tundra disturbance should occur during bird nesting season (June 1 to and road improvement activities be planned outside the period from June 1 to July 31 to minimize
July 31). noise impacts to nesting birds.
For FAA airstrip construction, snow removal and the first layer of gravel for the entire
airstrip footprint should take place in late May, prior to the onset of the bird nesting
season. Additional gravel layers within the footprint can then be placed and compacted
throughout the summer without damage to birds and habitats.
63 Water resources Prevent ponding of sheet flow and Place culverts within long linear roads in sufficient number to prevent ponding of No Design Measure 27 requires CPAI to install cross-drainage culverts as needed to maintain natural
maintain natural flow during rain events sheet-flow and to maintain natural flow throughout break-up and summer/fall rain surface drainage to mitigate the risk of sheet flow interruption and thermokarsting. The estimated
events. spacing of culverts is approximately every 1,000 feet; however, exact placement would be adjusted
based on a field survey of in-field local drainage patterns.
64 Water resources Prevent high-water erosion of roads/pads Place erosion control material (e.g., supersacks, revetment) on banks of rivers under No Design Measure 40 requires that CPAI produce an adaptive erosion control plan that incorporates
and stream bottoms and adjacent to bridges and adjacent to and on bottom of stream approach and exit of plans for use of each type of erosion control. While the use of supersacks and erosion control mats
large culvers (when necessary) to prevent high-water erosion of road or pad and can result in a temporary reduction in erosion activities, their use can cause subsequent adverse
stream bottom. impacts to fish passage. All culvert designs for the project adhere to Alaska Department of
Transportation and Public Facilities Alaska Highway Drainage Manual (ADOT&PF 2006). This
document includes erosion control best management practices as well as a section outlining bank
protection types (e.g., sand/concrete sacks, revetments) and design guidelines for each protection
type.
Draft (Yes/No)
Supplemental
EIS
65 Water resources Protect surface waters Prohibit the discharge of any contact fluids into surface waters. No ROP A-2 requires that all pumpable solid, liquid, and sludge waste be disposed of by injection in
accordance with EPA and State of Alaska regulations and procedures. On pad temporary muds and
cuttings storage, as approved by ADEC, will be allowed as necessary to facilitate annular injection
and or backhaul operations. Wastewater discharges or disposal of domestic wastewater into bodies
of fresh, estuarine, and marine waters, including wetlands, are prohibited unless authorized by a
National Pollutant Discharge Elimination System or State permit.
66 Soils Implementation of an Adaptive Implement an adaptive management plan that includes regular monitoring and is No Monitoring for thawing and thermokarst impacts to project infrastructure is part of CPAI’s road
Management Plan responsive to floodplain impacts, thermokarst development, changes in hydrology, maintenance approach. In addition to CPAI monitoring obligations, BLM maintains its own
vegetation damage, seasonal flows, water levels, erosion, deposition throughout the soil/snow monitoring network within NPR-A which is used to consistently monitor conditions for
Project area. the duration of the winter development season. BLM releases a weekly, publicly viewable, report
with soil temperature and snow depth data which is shared with industry, other agencies, and the
public. BLM also conducts annual, winter and summer, inspections of ROWs permitted in NPR-A
with a heightened emphasis placed on winter road construction and observable vegetative recovery.
Industry also conducts its own geotechnical analysis for new development proposals. These
analyses allow for identification of site-specific issues such as thaw unstable soils and are used for
both routing and engineering design. Implementation of these efforts sufficiently meets the
objective. Special Condition 11 of the USACE Section 404 requires that the natural drainage
patterns be maintained along access roads and pads, and if there is evidence of altered hydrology
(such as excessive ponding, drying, channelization), CPAI is required to restore hydrology to
preconstruction conditions. NSB Rezone Required Measure 31 requires monitoring for
sedimentation buildup. Implementation of these measures sufficiently meets the objective.
67 Public health Food Security Provide gravel and building materials for construction of a public greenhouse suitable No This measure does not mitigate known project effects. Consistent with the provisions of 43 CFR
for Arctic conditions, to protect food security and allow communities to better adapt to 3600, the BLM cannot compel the holder of a mineral sales contract to provide gravel resources to
the future climate through the establishment of local fresh food production. users other than the contract holder. Such a project would be more properly supported through
NPR-A Impact Mitigation Fund grants.
Notes: ADEC (Alaska Department of Environmental Conservation); ADF&G (Alaska Department of Fish and Game); ADNR (Alaska Department of Natural Resources); BLM (Bureau of Land Management); CPAI (ConocoPhillips Alaska, Inc.); EIS (Environmental Impact Statement); EPA (U.S. Environmental
Protection Agency); FAA (Federal Aviation Administration); GPS (global positioning system); IAP (Integrated Activity Plan); KSOP (Kuukpik Subsistence Oversight Panel); Kuukpik (Kuukpik Corporation); mph (miles per hour); NEPA (National Environmental Policy Act) No. (number); NPR-A (National
Petroleum Reserve in Alaska); NSB (North Slope Borough); NVN (Native Village of Nuiqsut); ROD (Record of Decision); ROP (required operating procedure); ROW (right of way); TLCHA (Teshekpuk Lake Caribou Habitat Area); TLSA (Teshekpuk Lake Special Area); USACE (U.S. Army Corps of
Engineers).
4.2 Suggested Mitigation Measures from Public Comments on the 2022 Willow MDP Draft Supplemental Environmental Impact Statement
Table 4.3 provides the suggested mitigation measures identified in public comments on the 2022 Willow MDP Draft Supplemental EIS.
Table 4.3. Public Comment Period Suggested Mitigation Measures
No. Affected Resource(s) Objective Standard/Requirement Adopted Rationale For or Against Adoption
(Yes/No)
1 Water resources Implement an adaptive Implement an adaptive management plan that addresses surface water blockages around Project infrastructure. No Measure 6 as adopted in this ROD ensures that culverts, bridges, and pipeline stream
management plan to crossings are designed in such a manner as to reduce unanticipated surface water flow
address surface water blockages. Special Condition 11 of the USACE Section 404 permit requires that the natural
blockages. drainage patterns be maintained along access roads and pads, and if there is evidence of
altered hydrology (such as excessive ponding, drying, channelization), CPAI is required to
restore hydrology to preconstruction conditions. Adherence to this measure and condition
sufficiently meets the objective.

(Yes/No)
2 Climate change Monitor for permafrost Implement an adaptive management plan that addresses monitoring potential permafrost thawing and thermokarst No Monitoring for thawing and thermokarst impacts to project infrastructure is a requirement
thaw and implement an impacts for all Project structures, including roads, pads, and the constructed freshwater reservoir (under of CPAI’s road maintenance policy. In addition to CPAI monitoring obligations, BLM
adaptive management plan Alternatives B, C, and D) to further protect the TLSA. Share monitoring information with ADF&G and other maintains its own soil/snow monitoring network within NPR-A which is used to
to address identified relevant agencies. consistently monitor conditions for the duration of the winter development season. BLM
permafrost thaw and releases a weekly, publicly viewable, report with soil temperature and snow depth data
thermokarsting. which is shared with industry, other agencies, and the public. BLM also conducts annual,
winter and summer, inspections of ROWs permitted in NPR-A with a heightened emphasis
placed on winter road construction and observable vegetative recovery. Industry also
conducts its own geotechnical analysis for new development proposals. These analyses
allow for identification of site-specific issues such as thaw unstable soils and are used for
both routing and engineering design. Implementation of these efforts sufficiently meets the
objective.
3 Birds Limit the disturbance of Limit road upgrades to times outside of the bird nesting season (generally July 1 through July 31). Yes See Measure 16.
tundra-nesting birds.
4 Subsistence Provide access to gravel Permittee shall stockpile excess gravel from open cells at the Tinmiaqsiugvik mine site for use in community No This measure does not mitigate known project effects. Consistent with the provisions of 43
resources for local infrastructure projects. The permittee would operate the mine site on behalf of the community, and the CFR 3600, the BLM cannot compel the holder of a mineral sales contract to provide gravel
community infrastructure community shall be responsible for obtaining a mineral materials sales contract from BLM. resources to users other than the contract holder.
projects.
5 Subsistence; Air quality; Improve access for Provide the State of Alaska’s Community Winter Access Trail access to Willow gravel and ice road infrastructure No Design Measure 77 stipulates that CPAI will allow Nuiqsut residents reasonable use of
Climate change subsistence users and for use to reduce the reliance on constructing snow roads through the Willow Project area. Project roads to access subsistence areas throughout the life of the Project. Use of the road
reduce the need for snow is provided in support of continuing subsistence activities to mitigate restrictions to
road construction. subsistence access to the community of Nuiqsut. Expanding access to include all NSB
residents does not mitigate known project impacts. Increased user traffic of project roads
may result in increased safety risks.
6 Wildlife; Subsistence Reduce helicopter and Use unmanned aerial vehicles (i.e., drones) to conduct inspections and surveys to the greatest extent practicable to Yes See Measure 24.
fixed-wing aircraft flight reduce impacts to wildlife and subsistence users.
impacts to wildlife and
subsistence users.
7 Invasive species Prevent spread of invasive Use existing and temporary indoor and outdoor vehicle washing facilities and inspection stations in locations as Yes See Measure 12.
species in the Project area. needed to wash and inspect vehicles prior to use in the Project area. Permittee will follow an Invasive Species
Monitoring Control Plan for vehicle washing practices and to monitor for invasive species.
8 Climate change Reduce downstream The Willow project would cease producing oil 20 years from the date of the spudding of the first well. No All project alternatives are designed and evaluated based on a full 30-year field life
greenhouse gas emissions consistent with the Master Development Plan for the Bear Tooth Unit. Selection of
resulting from the Willow Alternative E would reduce both the scope and scale of development and resulting
Project. production, thereby reducing GHG emissions.

(Yes/No)
9 Climate change Reduce net greenhouse gas Permittee shall offset 50% of the projected net GHG emissions associated with the final preferred alternative No This measure conflicts with and duplicates current initiatives, both from the industry
emissions resulting from selected in the Project’s ROD, in accordance with U.S. commitments under the Paris Agreement. GHGs shall be and government perspective. It takes a narrow and prescriptive approach to what is a
the Willow Project. offset through reforestation of land (as opposed to preservation of existing forest land), and the required acreage layered, extremely complex, and evolving policy and technical area guided by industry
of reforestation necessary to offset the Project’s GHG’s shall be calculated by assuming that the average mature practice, government policy and regulation.
tree can sequester (i.e., consume and retain) up to 48 pounds of carbon dioxide per year (European Environment
Agency 2011). In its 2022 budget justification, the U.S. Forest Service reported that the National Forest System’s The applicant has already committed to net-zero GHG emissions by 2050 on a
reforestation needs are estimated at 4 million acres (USFS 2021). These efforts are accomplished with the help of portfolio-wide basis, specifically by reducing/offsetting direct operational GHG
non-profit partners such as the National Forest Foundation and civic groups who contribute to the agency’s emissions (termed Scope 1 and 2 emissions as defined by the Greenhouse Gas
capacity for reforestation through partnerships and matching fund agreements. Implementation of this mitigation Protocol: A Corporate Accounting and Reporting Standard). The Willow project is
measure would require the permittee to offset 50% of the projected net GHG emissions associated with the included in this portfolio-wide approach. This includes both emissions reduction
Project (approximately 69 to 73 million metric tons of net CO2e compared to Alternative A, depending on the activities as well as emissions offsets. This approach is well documented and reported to
action alternative and choice of global warming potential). The U.S. has established an economy-wide target of the EPA on a regular basis, and includes short term (by 2025), medium term (by 2030),
reducing its net GHG emissions by 50% to 52% below 2005 levels in 2030 in its Nationally Determined and long term (by 2050) reductions. In effect, the objective stated above is already met,
Contributions under the Paris Agreement (UNFCCC 2021); offsetting 50% of the net Willow emissions over the and this new measure would duplicate the existing effort.
life of the Project would help the U.S. achieve this goal.
The applicant’s net zero commitments are consistent with and guided by both industry-
wide and government-wide efforts to reduce operational emissions, including emissions
produced as result of downstream combustion of oil from projects like Willow.
Requiring the offset of downstream emissions (i.e., indirect emissions) from the Willow
project would be redundant to the reduction/offset efforts of the end-users of Willow
oil. In other words, including the downstream consumption or burning of Willow oil
(often referred to as Scope 3 emissions) – as is done in the measure above – would
result in double counting the same emissions.
Finally, this measure would not be feasible for BLM to enforce. It requires the sort of
government-wide cooperation and goal setting that is already occurring by those best
positioned to directly regulate and guide such initiatives, such as the EPA and the SEC.
10 Climate change; Increase food security by Permittee shall work with the local community to improve food storage capacity and durability. This could No This measure does not mitigate known project effects. Consistent with the provisions of 43
Subsistence providing adaptive include providing gravel and insulation to "harden" existing cellars, providing transportation of chest freezers to CFR 3600, the BLM cannot compel the holder of a mineral sales contract to provide gravel
measures for food storage the North Slope, etc. resources to users other than the contract holder.
11 Hazardous materials Facilitate clean-up of Permittee shall work with the BLM to facilitate access to contaminated sites using temporary and permanent No This measure does not mitigate known project effects. BLM is responsible for cleanup of
historic contamination. Willow Project infrastructure to promote clean-up efforts. historic or legacy contamination on BLM-managed lands within the NPR-A.
12 Soil; Wetlands and Minimize impacts to soils Permittee would provide BLM with as-built GIS of snow and ice infrastructure at the end of every winter season. No ROP C-2 and the reporting parameters outlined in the Vehicle Use required under NSB
vegetation and vegetation from snow Ice road and pad alignments shall be different every year to minimize impacts to soils and vegetation unless Rezoning Condition of Approval 3 sufficiently meet the objective to impacts to soils and
and ice infrastructure. otherwise approved by the BLM authorized officer. Snow roads may use the same alignment year to year vegetation from snow and ice infrastructure.
depending on snow conditions.
13 Subsistence Provide North Slope Permittee shall allow reasonable access to North Slope residents to use ice roads built for the Willow Project, No Design Measure 77 stipulates that CPAI will allow Nuiqsut residents reasonable use of
residents access to Colville including the annual Colville River ice bridge. Project roads to access subsistence areas throughout the life of the Project. Use of road is
River ice road crossings. provided in support of continuing subsistence activities to mitigate restrictions to
subsistence access to the community of Nuiqsut. Expanding access to include all NSB
residents does not mitigate known project impacts. Increased user traffic of project roads
may result in increased safety risks.
14 Air quality; Climate Reduce methane emissions Permittee shall use the best available technology to reduce venting of methane to the atmosphere during wellhead No Design Measure 120 requires that CPAI minimize vented methane gas volumes by initially
change from project activities. and processing facility maintenance. Remote inspections of pipelines and well-pads will occur once per quarter to depressurizing pipelines to the production system, flare, and then purge lines with nitrogen
inspect for methane leaks. prior to opening. By using nitrogen sweep and purge, little to no natural gas should be
released when opening the equipment to atmosphere. Design Measure 128 requires CPAI
to conduct leak surveys (including methane) in accordance with New Source Performance
Standard (40 CFR 60 OOOOa or OOOOb [whichever regulation is applicable at the time]).
Implementation of these measures sufficiently meets the objective to reduce methane
emissions from project activities.
15 Water quality; Fish; Monitor water quality for Develop a water quality monitoring plan to regularly sample area waterways for contamination downstream from No Water quality protection and monitoring is the purview of the ADEC. Testing and
Subsistence contamination. Project facilities. monitoring of all freshwater sources that intersect or are downstream from the project is not
reasonable and does not mitigate known project effects.

(Yes/No)
16 Economics Provided targeted Provide job training, hiring events, and outreach to local residents in the NSB. These employment outreach efforts No BLM does not have the authority to require an applicant to hire locals. Design Measures 74
employment opportunities will include training for upcoming Project positions, as well as engagement with locally owned support service commit CPAI to continued support of the internship program (CareerQuest) to introduce
for NSB residents, companies to provide an overview of the types of Project support that will be required. Employment outreach in Nuiqsut high school students to jobs and careers in the oil fields and in their community.
particularly Nuiqsut Nuiqsut will be held at least once per year. Design Measure 75 commits CPAI to continue to strive to hire qualified Nuiqsut, NSB, and
residents. Alaska residents for oil field jobs.
17 Wetlands and vegetation; Protect stream banks, a. Off-road travel will be allowed by the BLM authorized officer when soils are frozen to sufficient depth No ROP C-2 and the reporting parameters outlined in the Vehicle Use required under NSB
Birds; Terrestrial minimize compaction of (defined by a soil temperature of 23 degrees Fahrenheit or lower at a depth of 12 inches), and 6 inches of Rezoning Condition of Approval 3 sufficiently meet the objective.
mammals; Subsistence soils, and minimize snow cover exists. Snow distribution and pre-packing may be used to maintain sufficient snow cover in areas
breakage, abrasion, of poor snow coverage. The permittee shall submit data to BLM to show that these conditions have been
compaction, and reached prior to conducting work. Snow survey and soil freeze-down data collected for ice road or snow trail
displacement of vegetation planning and monitoring shall be submitted to BLM with the required weekly report of operations.
resulting from winter b. Off-road travel is generally to be conducted with low-ground-pressure vehicles unless otherwise approved by
tundra travel. the BLM authorized officer. Low-ground pressure is defined as vehicles with less than 4 pounds per square
inch ground pressure, or vehicles that have passed the Alaska Department of Natural Resources low-pressure
vehicle qualification certification.
c. Ice roads would be designed and located to avoid the most sensitive and easily damaged tundra types, as
much as practicable.
d. The permittee shall provide the BLM with an as-built of all ice roads, snow trails, and ice pads after the
infrastructure is completed. Data must be in a GIS format (ESRI shapefiles referencing the North American
Datum of 1983).
18 Marine mammals Minimize impacts to Permittee will conduct two airborne infrared surveys for polar bear dens prior to initiating winter activities. Yes See Measure 25.
denning polar bears.
19 Water resources; Fish; Minimize impacts to Develop a maintenance plan for boat ramps to ensure the long-term viability and use of the site(s) while Yes See Measure 11.
Marine mammals; streams from Project boat minimizing impacts to the adjacent waterbodies. The initial plan shall be submitted to the BLM authorized officer
Subsistence ramps. 60 days prior to initiating the first year’s maintenance activities. Any substantive changes to the maintenance plan
will be submitted to BLM prior to initiation of maintenance activities impacted by those changes. The plan will
include such measure as:
a. Determine if erosion mitigation features or options in engineering design of boat ramp(s) are needed to
prevent or minimize erosion potential at the boat ramp(s) and along adjacent riverbanks. Describe the
evaluation that was completed to determine if erosion control is needed and what type of features are
included in the final design.
b. Identify entity responsible for site maintenance.
c. Describe annual maintenance (grading) of parking pads, turning pads, access ramps, and road access.
d. Identify the gravel source for reinforcement of boat ramps and pads when necessary. Describe the location
and quantity of gravel available and the frequency of how often the need for additional gravel will be
evaluated.
e. Include regular clean-up of pads and surroundings, including back-haul of trash to suitable disposal site.
f. Describe how spills will be removed or mediated per the Project’s spill plan.
20 Economics; Provide economic Permittee shall support economic development workshops focused on identifying and developing small business No This measure does not mitigate known project effects.
Environmental justice development opportunities ideas that are not dependent on the extraction industry. Workshops will provide information about how to apply
in the community of for small business grants, how to craft a business plan, etc.
Nuiqsut.
21 Soil; Wetlands and Reduce impacts from CPAI will evaluate the use of a surface miner at the Tiŋmiaqsiuġvik mine site to develop the gravel resource. Yes See Measure 26.
vegetation blasting at the Willow CPAI will use a surface miner at the Kuparuk Mine Site during the 22-23 winter season and shall provide a report
Mine Site. to BLM on the efficacy of this equipment in North Slope conditions no later than June 2023. The report shall
describe how the equipment was used, any engineering or logistical challenges of using this equipment and steps
taken to adapt the surface miner for use in North Slope operations. BLM engineers may conduct on the ground
inspections to observe the surface miner during the winter 22-23 season. If the surface miner is determined to be
technologically feasible as an alternative to blasting, the BLM will require its use at the Willow Mine Site to
reduce the impacts of blasting (blasting would still be required to remove overburden).

(Yes/No)
22 Visual Resources; Water Permanently protect the BLM will develop compensatory mitigation that provides durable, long-term protection for the Teshekpuk Yes See Measure 27.
Resources; most important habitat Caribou Herd to fully offset impacts of the project on that Herd, to include protecting the surface area of
Wetlands/Vegetation; areas for the maternal and Teshekpuk Lake, a buffer along all shores of the lake, and the K-10 Caribou Movement Corridors/K-16 Deferral
Birds, Terrestrial migrating caribou of the Areas (under Alternative E in the 2020 NPR-A Integrated Activity Plan Final Environmental Impact Statement)
Mammals; Marine Teshekpuk Caribou Herd, using existing statutory, management or administrative authorities, with a focus on restricting future leasing or
Mammals; Land including Teshekpuk Lake, surface development in those areas.
Ownership & Use; a buffer around the lake,
Subsistence; and the migration corridors
Environmental Justice; and to the east and northwest.
Wilderness Characteristics
Notes: ADEC (Alaska Department of Environmental Conservation); ADF&G (Alaska Department of Fish and Game); BLM (Bureau of Land Management); CO2e (carbon dioxide equivalent); CPAI (ConocoPhillips Alaska, Inc.); EPA (Environmental Protection Agency); GHG (greenhouse gases); GIS
(geographic information system); No. (number); NPR-A (National Petroleum Reserve in Alaska); NSB (North Slope Borough); ROD (Record of Decision); ROP (required operating procedure); ROW (right of way); SEC (Securities and Exchange Commission); TLSA (Teshekpuk Lake Special Area);
USACE (U.S. Army Corps of Engineers).

5.0 OTHER REQUIRED MITIGATION MEASURES

5.1 Mitigation Measures in Support of Endangered Species Act Section 7
5.1.1 Measures from Section 7 Consultation: U.S. Fish and Wildlife Service
The following reasonable and prudent measure contained in the USFWS’s Biological Opinion (USFWS 2023) for
the Project is applicable to the Project:
Reasonable and Prudent Measure 1: Contribute to improved understanding of spectacled eider collision risk
with Project infrastructure, facilities, and/or vessels.
To be exempt from the prohibitions of Section 9 of the Act, BLM, the U.S. Army Corps of Engineers, and their
agents must comply with the following terms and conditions, which implement the Reasonable and Prudent
Measure described above. These terms and conditions are non-discretionary.
Term and Condition 1: Observations of collision events in which one or more listed eider, or 3 or more birds of
any species, appear to have collided with oil and gas infrastructure (i.e., wires, towers, or buildings), or vessels
shall be recorded and reported to the USFWS, Northern Alaska Field Office and BLM, Arctic District Office in
an annual report due by December 31, unless listed eider collisions exceed the number exempted by the Incidental
Take Statement (ITS), in which case, the collision event shall be reported within 48 hours. Reports should
include: the date, time of day, weather conditions, number and species of birds involved, and other factors
considered to be relevant by the observer, and should include photos of dead birds, top and bottom view, with
wings spread, and with the bill and feet visible if possible.
5.1.2 Measures from Section 7 Consultation: National Marine Fisheries Service

Additional measures, described below, resulted from BLM’s Section 7 consultation with the National Marine
Fisheries Service (NMFS) for the Project (NMFS 2023) and are hereby adopted.
General Mitigation Measures

1. The BLM will inform NMFS of impending in-water activities a minimum of one week prior to the onset
of those activities.
2. If construction activities will occur outside of the time window specified in this letter (i.e., outside of June
15 through October 15 of project years), the applicant will notify NMFS of the changed action at least 60
days prior to the end of the specified time window to allow for reinitiation of consultation.
3. Project-associated staff will cut all materials that form closed loops (e.g., plastic packing bands, rubber
bands, and all other loops) prior to proper disposal in a closed and secured trash bin. Trash bins will be
properly secured with locked or secured lids that cannot blow open, preventing trash from entering into
the environment, thus reducing the risk of entanglement in the event that waste enters marine waters.
4. Project-associated staff will properly secure all ropes, nets, and other marine mammal entanglement
hazards to ensure they do not blow or wash overboard.
Protected Species Observer (PSO) Measures

5. One or more PSOs will perform PSO duties onsite throughout barge transit, screeding, and lightering.
6. For each in-water activity, PSOs will monitor all marine waters within the indicated shutdown zone
radius for that activity (Table 5.1).
Table 5.1. Shutdown Zones for Each Activity
Activity Zone Radius
Screeding 300 meters

7. PSOs will be positioned such that they will collectively be able to monitor the entirety of the shutdown
zone. The action agency will coordinate with NMFS on the placement of PSOs prior to commencing in-
water work.
8. Prior to commencing screeding, PSOs will scan waters within the 300 m shutdown zone and confirm no
listed species are within the shutdown zone for at least 30 minutes immediately prior to initiation of the
in-water activity. If one or more listed species are observed within the shutdown zone, the in-water
activity will not begin until the listed species exit the shutdown zone of their own accord, or the shutdown
zone has remained clear of listed species for 30 minutes immediately prior to screeding or lightering.
9. This pre-construction activity observation period will take place at the start of each day of in-water
activities, each time in-water activities have been shut down or delayed due the presence of a listed
species, and following cessation of in-water activities for a period of 30 minutes or longer.
10. The on-duty PSOs will continuously monitor the shutdown zone and adjacent waters during screeding
operations for the presence of listed species.
11. In-water activities will take place only:
a. between local sunrise and sunset (but see measure 13);
b. during conditions with a Beaufort Sea State of 4 or less; and
c. when the entire shutdown zone and adjacent waters are visible (e.g., monitoring effectiveness is
not reduced due to rain, fog, snow, haze or other environmental/atmospheric conditions).
12. If visibility degrades such that a PSO can no longer ensure that the shutdown zone remains devoid of
listed species during screeding, the crew will cease in-water work until the entire shutdown zone is visible
and the PSO has indicated that the zone has remained devoid of listed species for 30 minutes.
13. If lightering occurs outside local sunrise and sunset, PSOs will be provided with night vision equipment
(e.g., night vision binoculars, monocles, or spotting scopes) to support viewing and maintaining the
nearshore area.
14. The PSO will order the screeding activities to immediately cease if one or more listed species has entered,
or appears likely to enter, the associated shutdown zone.
15. If screeding activities are shut down for less than 30 minutes due to the presence of listed species in the
shutdown zone, screeding may commence when the PSO provides assurance that listed species were
observed exiting the shutdown zone. Otherwise, the activities may only commence after the PSO provides
assurance that listed species have not been seen in the shutdown zone for 30 minutes (for cetaceans) or 15
minutes (for pinnipeds).
16. Following a lapse of screeding activities of more than 30 minutes, the PSO will authorize resumption of
activities only after the PSO provides assurance that listed species have not been present in the shutdown
zone for at least 30 minutes immediately prior to resumption of operations.
17. If a listed species is observed within a shutdown zone or is otherwise harassed, harmed, injured, or
disturbed, PSOs will report that occurrence to NMFS within one business day using the contact
information specified in Table 3.
18. PSOs must be independent (i.e., not construction personnel or vessel operators) and have no other
assigned tasks during monitoring periods.
19. The action agency or its designated non-federal representative will provide resumes or qualifications of
PSO candidates to the NMFS consultation biologist or section 7 coordinator for approval at least one
week prior to in-water work. NMFS will provide a brief explanation of lack of approval in instances
where an individual is not approved.
20. At least one PSO will have prior experience performing the duties of a PSO during construction activity.

21. At least one PSO on the project will complete PSO training prior to deployment. The training will
include:
a. field identification of marine mammals and marine mammal behavior;
b. ecological information on marine mammals and specifics on the ecology and management
concerns of those marine mammals;
c. ESA and MMPA regulations;
d. proper equipment use;
e. methodologies in marine mammal observation and data recording and proper reporting protocols;
and
f. an overview of PSO roles and responsibilities.
22. PSOs will:
a. have vision that allows for adequate monitoring of the entire 300 m zone for screeding;
b. have the ability to effectively communicate orally, by radio and in person, with project personnel;
c. be able to collect field observations and record field data accurately and in accordance with
project protocols;
d. be able to identify to species all marine mammals that occur in the action area;
e. have writing skills sufficient to create understandable records of observations
23. PSOs will work in shifts lasting no longer than 4 hours with at least a 1-hour break from monitoring
duties between shifts. PSOs will not perform PSO duties for more than 12 hours in a 24‐hour period.
24. PSOs will have the ability and authority to order appropriate mitigation responses, including shutdowns,
to avoid takes of all listed species.
25. The PSOs will have the following equipment to address their duties:
a. tools which enable them to accurately determine the position of a marine mammal in relationship
to the shutdown zone;
b. two-way radio communication, or equivalent, with onsite project manager;
c. tide tables for the project area;
d. watch or chronometer;
e. binoculars (7x50 or higher magnification) with built-in rangefinder or reticles (rangefinder may
be provided separately);
f. night vision binoculars, monocles, or spotting scopes;
g. instruments that allow observer to determine geographic coordinates of observed marine
mammals;
h. a legible copy of this LOC and all appendices;
i. legible and fillable observation record form allowing for required PSO data entry.
26. Prior to commencing in-water work or at changes in watch, PSOs will establish a point of contact with the
construction crew. The PSO will brief the point of contact as to the shutdown procedures if listed species
are observed likely to enter or within the shutdown zone, and will request that the point of contact instruct
the crew to notify the PSO when a marine mammal is observed. If the point of contact goes "off shift" and
delegates his duties, the PSO must be informed and brief the new point of contact.

Dredging/Screeding
27. All vessels involved in dredging, screeding, and underwater excavating operations, including survey
vessels, will transit at velocities below 10 knots.
28. Dredging, screeding and underwater excavating activities must shut down whenever a listed marine
mammal approaches within 300 m.
Vessels1
29. Vessel operators will:
a. maintain a watch for marine mammals at all times while underway;
b. stay at least 91 m (100 yds) away from listed marine mammals, except they will remain at least
460 m (500 yards) from endangered North Pacific right whales;
c. travel at less than 5 knots (9 km/hour) when within 274 m (300 yards) of a whale;
d. avoid changes in direction and speed when within 274 m (300 yds) of a whale, unless doing so is
necessary for maritime safety;
e. not position vessel(s) in the path of a whale, and will not cut in front of a whale in a way or at a
distance that causes the whale to change direction of travel or behavior (including
breathing/surfacing pattern);
f. check the waters immediately adjacent to the vessel(s) to ensure that no whales will be injured
when the propellers are engaged;
g. reduce vessel speed to 10 knots or less when weather conditions reduce visibility to 1.6 km (1 mi)
or less;
30. Adhere to the Alaska Humpback Whale Approach Regulations when vessels are transiting to and from
the project site: (see 50 CFR §§ 216.18, 223.214, and 224.103(b)) (note: these regulations apply to all
humpback whales). Specifically, pilot and crew will not:
a. approach, by any means, including by interception (i.e., placing a vessel in the path of an
oncoming humpback whale), within 100 yards of any humpback whale;
b. cause a vessel or other object to approach within 100 yards of a humpback whale; or
c. disrupt the normal behavior or prior activity of a whale by any other act or omission.
31. If a whale’s course and speed are such that it will likely cross in front of a vessel that is underway, or
approach within 91 m (100 yds) of the vessel, and if maritime conditions safely allow, the engine will be
put in neutral and the whale will be allowed to pass beyond the vessel, except that vessels will remain 460
m (500 yds) from North Pacific right whales.
32. Vessels will take reasonable steps to alert other vessels in the vicinity of whale(s).
33. Vessels will not allow lines to remain in the water unless both ends are under tension and affixed to
vessels or gear. No materials capable of becoming entangled around marine mammals will be discarded
into marine waters.
Vessel Transit, North Pacific Right Whales, and their Critical Habitat
34. Vessels will:
a. remain at least 460 m (500 yards) from North Pacific right whales.
b. avoid transiting through designated North Pacific right whale critical habitat if practicable (50
CFR 226.215). If traveling through North Pacific right whale critical habitat cannot be avoided,
vessels will:
1
Vessel measures will be implemented provided doing so does not endanger the vessel or crew.
i. travel through North Pacific right whale critical habitat at 5 knots or less; or at 10 knots
or less while PSOs maintain a constant watch for marine mammals from the bridge;
ii. maintain a log indicating the time and geographic coordinates at which vessels enter
and exit North Pacific right whale critical habitat.
Vessel Transit, Western DPS Steller Sea Lions, and their Critical Habitat.
35. Vessels will not approach within 5.5 km (3 nm) of rookery sites listed in (50 CFR § 224.103(d)).
36. Vessels will not approach within 914 m (3,000 ft) of any Steller sea lion haulout or rookery which is not
listed in 50 CFR § 224.103(d)).
General Data Collection and Reporting
Data Collection
37. PSOs will record observations on data forms or into electronic data sheets.
38. The action agency will ensure that PSO data will be submitted electronically in a format that can be
queried such as a spreadsheet or database (i.e., digital images of data sheets are not sufficient).
39. PSOs will record the following:
a. the date, shift start time, shift stop time, and PSO identifier;
b. date and time of each reportable event (e.g., a marine mammal observation, operation shutdown,
reason for operation shutdown, change in weather);
c. weather parameters (e.g., percent cloud cover, percent glare, visibility) and sea state where the
Beaufort Wind Force Scale will be used to determine sea-state
(https://www.weather.gov/mfl/beaufort);
d. species, numbers, and, if possible, sex and age class of observed marine mammals, and
observation date, time, and location;
e. the predominant anthropogenic sound-producing activities occurring during each marine mammal
observation;
f. bearing and direction of travel of observed marine mammal(s);
g. observations of marine mammal behaviors and reactions to anthropogenic sounds and presence;
h. initial, closest, and last location of marine mammals, including distance from observer to the
marine mammal, and minimum distance from the predominant sound-producing activity or
activities to marine mammals;
i. whether the presence of marine mammals necessitated the implementation of mitigation measures
to avoid acoustic impact, and the duration of time that normal operations were affected by the
presence of marine mammals;
j. geographic coordinates for the observed animals, with the position recorded by using the most
precise coordinates practicable (coordinates will be recorded in decimal degrees, or similar
standard and defined coordinate system).
Data Reporting
40. All observations of North Pacific right whales (including in critical habitat) will be reported to NMFS
within 24 hours. These observation reports will include the following information:
a. date, time, and geographic coordinates of the observation(s);
b. number of North Pacific right whales observed, including number of adults/juveniles/calves
observed, if determinable;

c. Environmental conditions as they existed during each observation event, including sea conditions,
weather conditions, visibility, lighting conditions, and percent ice cover;
d. Photos and videos of the whales if possible.
41. If project vessels are travelling within North Pacific right whale critical habitat in a manner that requires
the use of PSOs (i.e., vessel is travelling within North Pacific right whale critical habitat at greater than 5
kts), PSOs will collect, organize, and report on vessel travel within North Pacific right whale critical
habitat and on non-North Pacific right whale marine mammal observations made within that critical
habitat. These reports will be submitted to [email protected] by the end of the calendar year. The
report will outline the following information:
a. species, date, and time for each observation;
b. number of animals per observation event; and number of adults/juveniles/calves per observation
event (if determinable);
c. geographic coordinates for the observed animals, with the position recorded by using the most
precise coordinates practicable (coordinates will be recorded in
42. Observations of humpback whales will be transmitted to [email protected] by the end of the
calendar year, including information specified in General Data Collection and Reporting (above) and
photographs and videos obtained of humpback whales, most notably those of the whale’s flukes.
Unauthorized Take
43. If a listed marine mammal is determined by the PSO to have been disturbed, harassed, harmed, injured, or
killed (e.g., a listed marine mammal(s) is observed entering a shutdown zone before operations can be
shut down, or is injured or killed as a direct or indirect result of this action), the PSO will report the
incident to NMFS within one business day, with information submitted to [email protected]. These
PSO records will include:
a. all information to be provided in the final report (see Mitigation Measures under the Final Report
heading below):
b. number of animals of each threatened and endangered species affected;
c. the date, time, and location of each event (provide geographic coordinates);
d. description of the event;
e. the time the animal(s) was first observed or entered the shutdown zone, and, if known, the time
the animal was last seen or exited the zone, and the fate of the animal;
f. mitigation measures implemented prior to and after the animal was taken; and
g. if a vessel struck a marine mammal, the contact information for the PSO on duty, or the contact
information for the individual piloting the vessel if there was no PSO on duty;
h. Photographs or video footage of the animal(s) (if available).
Stranded, Injured, Sick or Dead Marine Mammal (not associated with the project)
44. If PSOs observe an injured, sick, or dead marine mammal (i.e., stranded marine mammal), they will
notify the Alaska Marine Mammal Stranding Hotline at 877-925-7773 (Table 3). The PSOs will submit
photos and available data to aid NMFS in determining how to respond to the stranded animal. If possible,
data submitted to NMFS in response to stranded marine mammals will include date/time, location of
stranded marine mammal, species and number of stranded marine mammals, description of the stranded
marine mammal’s condition, event type (e.g., entanglement, dead, floating), and behavior of live-stranded
marine mammals.

Illegal Activities
45. If PSOs observe marine mammals being disturbed, harassed, harmed, injured, or killed (e.g., feeding or
unauthorized harassment), these activities will be reported to NMFS Alaska Region Office of Law
Enforcement at 1-800-853-1964 (Table 3).
46. Data submitted to NMFS will include date/time, location, description of the event, and any photos or
videos taken.
Final Report
47. A draft of the final report will be submitted to NMFS within 90 calendar days of the completion of the
project (i.e., after Year 6 activities are complete) summarizing the data recorded and submitted to
[email protected]. A final report must be prepared and submitted within 30 calendar days
following receipt of any NMFS comments on the draft report. If no comments are received from NMFS
within 30 calendar days of receipt of the draft report, the report may be considered final. The report will
summarize all in-water activities associated with the proposed action, and results of PSO monitoring
conducted during the in‐water project activities.
48. The final report will include:
a. summaries of monitoring efforts, including dates and times of construction, dates and times of
monitoring, dates and times and duration of shutdowns due to marine mammal presence;
b. date and time of marine mammal observations, geographic coordinates of marine mammals at
their closest approach to the project site, marine mammal species, numbers, age/size/gender
categories (if determinable), and group sizes.
c. number of marine mammals observed (by species) during periods with and without project
activities (and other variables that could affect detectability);
d. observed marine mammal behaviors and movement types versus project activity at time of
observation;
e. numbers of marine mammal observations/individuals seen versus project activity at time of
observation
f. distribution of marine mammals around the action area versus project activity at time of
observation.
g. digital, queryable documents containing PSO observations and records, and digital, queryable
reports.
5.2 Mitigation Measures in Support of Magnuson-Stevens Fishery Conservation

and Management Act Essential Fish Habitat
In accordance with Section 305(b)(4)(A) of the Magnuson-Stevens Fishery Conservation and Management Act,
the BLM is hereby incorporating the following conservation recommendations to further avoid, minimize,
mitigate, or otherwise offset project related effects to Essential Fish Habitat (EFH) as recommended by NMFS
(BLM 2022b; NMFS 2022):
1. No in-water work 2 from August 15 through September 15 to protect migrating and early life stages of
Pacific salmon. The permit holder should coordinate with the State of Alaska Department of Fish and
Game (ADF&G) to refine the construction timing windows to the specific project area.
2
After additional discussion with NMFS personnel, it was clarified that the first recommended mitigation (i.e., no in-water
work) pertained only to riverine/freshwater EFH. Proposed construction activities (e.g., bridge construction, culvert
installation, and installation of seawater and diesel pipelines beneath the Colville River using horizontal directional drilling)
in areas identified as freshwater EFH would be conducted exclusively during winter using ice roads and pads. As such, the
BLM would adopt this recommended mitigation with the clarification that no in-water construction work would occur in

2. The permit holder should use stream simulation design for culverts and bridges, like the designs found
here: https://www.fws.gov/alaska-culvert-design-guidelines. These designs allow for construction of a
channel in new culverts at anadromous streams to support safe and timely migration past the project site. 3
5.3 Beaufort Sea Incidental Take Regulations

The current Beaufort Sea Incidental Take Regulations (ITRs) (86 FR 42982) for polar bears describe mitigation,
monitoring, and reporting requirements for oil and gas operators in the central Beaufort Sea and have been
important in mitigating impacts to polar bears from oil and gas activities.
Measures applicable to the Project are described below (see also Appendix E.13, Section 1.4). These measures
include all mitigation measures typically required to be implemented in accordance with MMPA authorization for
incidental take of marine mammals and take by deterrence of polar bears. These measures would be required for
the life of the Project (approximately 30 years). BLM would apply these mitigation measures to the Project and
support additional mitigation measures included in future ITRs in the analysis area.
Implementation of these measures does not depend on future MMPA authorizations; implementation of these
measures would occur regardless of future authorizations. Should future authorizations require additional
mitigation, those would also be implemented but are not included here.
5.3.1 Measures to Avoid and Minimize Potential Polar Bear Incidental Harassment
The following measures summarized below would be employed to avoid and minimize potential polar bear
incidental harassment:
1. Project activities would be conducted in accordance with CPAI’s Polar Bear Avoidance and Interaction
Plan (June 2021). A copy of this plan would be kept on-site and would be available for reference by all
Project personnel.
2. All employees, contractors, and personnel performing activities for the Willow Project would observe and
carry out all applicable terms and conditions currently set forth in 50 CFR 18 subpart J, Mitigation,
Monitoring, and Reporting Requirements for the 2021-2026 Beaufort Sea Incidental Take Regulations. The
terms and conditions in the current set of ITRs would be implemented for the 30-year Project life.
3. All personnel would limit encounters with polar bears by being observant of approaching polar bears and
by allowing polar bears to pass unhindered when possible.
4. If a polar bear interaction escalates into a life-threatening situation, MMPA section 101(c) allows, without
specific authorization, the take (including lethal take) of a polar bear if such taking is necessary for self-
defense or to save the life of a person in immediate danger. Such taking would be reported to USFWS and
BLM as soon as possible, but no later than 48 hours after the incident.
5. Work activities would not take place within 1.0 mile of known polar bear dens without prior authorization.
Two polar bear aerial infrared den detection surveys of all denning habitat within 1.0 mile of human
activity would be conducted during the maternal denning period (as specified in the 2021-2026 Beaufort
Sea ITR). These den detection surveys would be subject to weather restrictions or other factors but would
take place from approximately November 25 through January 20). Should occupied dens be identified
within 1.0 mile of Project activities at any time, work in the area will cease and BLM and USFWS Marine
Mammals Management would be contacted.
freshwater EFH from August 15 through September 15. Additional protections to fish and fish habitats would also be
provided by ADF&G Fish Habitat Permits, which are required as part of the permitting process for activities in waterbodies
that support anadromous fish.
3
In adopting this measure, the BLM notes that implementation of existing required operating procedures E-6 and E-14 and
Project design measures for culvert and bridge construction and siting, including adherence to Alaska Department of
Transportation culvert design guidelines (ADOT&PF 2006), would meet the USFWS design guidelines to support
anadromous and non-anadromous fish passage within the project area.

6. Vessel operators would maintain the maximum distance possible and take every precaution to avoid
harassment of concentrations of polar bears. Vessels would reduce speed and maintain a minimum 0.5-mile
operation exclusion zone around polar bears observed on ice.
BLM and USFWS would be notified of changes to the Project, including changes to activities, locations, or
methods, prior to implementation.
5.3.2 Measures to Avoid and Minimize Potential Polar Bear Deterrence

The following measures would be employed to avoid and minimize potential polar bear deterrence:
1. Project activities would be conducted in accordance with CPAI’s Polar Bear Avoidance and Interaction
Plan (June 2021). A copy of this plan would be kept on site and be available for reference by all Project
personnel.
2. CPAI would ensure that only trained and qualified personnel are assigned the task of polar bear deterrence.
Prior to initiation of activities, a list of trained personnel responsible for deterrence and a description of
their training would be submitted to USFWS Marine Mammals Management.
3. Should firearms be used for polar bear deterrence, CPAI would ensure that personnel comply with all laws
and regulations regarding the carry and use of firearms.
4. Within 48 hours of occurrence, CPAI or its designated agent, would document and report to USFWS
Marine Mammals Management all instances involving polar bear deterrence activities. A final report of all
polar bear deterrence activities would be submitted to BLM and USFWS Marine Mammals Management.
5. Appropriate deterrence techniques would include use of (but not limited to), bear monitors, airhorns,
electric fences, bear spray, acoustic recordings, vehicles, and projectiles (e.g., beanbags, rubber bullets,
“cracker” shells, “bangers”, and “screamers”). Deterrence techniques must not cause the injury or death of
a polar bear. Any injury or death of a polar bear would be reported to BLM and USFWS Marine Mammals
Management as soon as possible but no later than 48 hours after the incident.
6. Prior to conducting a deterrence activity, CPAI would:
a. Make a reasonable effort to reduce or eliminate attractants.
b. Secure the site, notify supervisor, and move personnel to safety.
c. Ensure the polar bear has escape route(s).
d. Ensure communication with all personnel.
7. When conducting a deterrence activity, CPAI would:
a. Never deter a polar bear for convenience or to aid Project activities. The safety and welfare of the
polar bear is second only to the safety and welfare of humans in a deterrence situation.
b. Shout at the polar bear before using projectiles or other techniques.
c. Begin with the lowest level of force or intensity that is effective and increase the force or
intensity of the technique, or use additional techniques, only as necessary to achieve the desired
result.
8. After a deterrence event, CPAI would:
a. Monitor the polar bear’s movement (to ensure no return).
b. Notify supervisor and personnel when it is safe to resume work.
c. Submit a report to USFWS Marine Mammals Management within 48 hours.
5.4 NSB Rezoning Required Mitigation Measures

As part of the North Slope Borough’s process to rezone the Willow Project area from Conservation District to
Resource District land use designation, the Project received additional review from the NSB. The NSB’s rezoning
approval included both required stipulations and mitigation measures and conditions of approval. These NSB
requirements are intended to further mitigate impacts to wildlife, subsistence use, and public health and safety
from the Project. These measures are not requirements of the BLM but are included here to provide a
comprehensive summary of required measures that serve to mitigate impacts from the Willow project.
Table 5.2 summarizes the NSB rezoning required stipulation and mitigation measures and Table 5.3 summarized
the NSB rezoning conditions of approval.

Table 5.2. North Slope Borough Rezoning Required Stipulations and Mitigation Measures
No. Category Stipulation or Mitigation Measure
1 Overall/General – Duck CPAI and its contractors shall place or affix permanent ownership identification and unique
Ponds numbering on every duck pond owned and used.
2 Overall/General – Mitigation CPAI shall mitigate the impacts on local residents related to the additional infrastructure in
Fund the area and the potential for reduction of subsistence resource availability, including the
impacts related to displacing resources from high priority subsistence use areas.
Commencing with the start of construction and continuing for the life the project, in
addition to any other agreements CPAI shall make annual payments in the amount of
$50,000 per year to a mitigation fund directed and administered by the NSB.
3 Subsistence – Access CPAI shall consult with the NSB, NVN, Kuukpik, and KSOP at least annually. Examples
of uses and developments requiring consultation include but are not limited to the
following: (1) construction of facilities and roads; (2) aircraft movement; (3) drilling; and
(4) the selection of water sources. Through this consultation, CPAI shall make reasonable
efforts to assure that planned activities are compatible with subsistence activities and will
not result in unreasonable interference with subsistence harvests or subsistence resources.
CPAI shall submit a report of this consultation, including areas of agreement and
identification of any unresolved conflicts, to the Administrator prior to the commencement
of the uses/developments at issue. The Administrator may take measures consistent with
NSB municipal code Title 19 to address any unresolved conflicts relating to said
uses/developments.
4 Subsistence – Due Diligence CPAI shall exercise due diligence to mitigate all adverse impacts on subsistence use
activities caused by CPAI's activities.
5 Subsistence – Timing To the maximum extent practical, initial project construction activities, such as construction
of gravel roads, pad, pipeline and bridges, will be done during the winter season.
6 Wildlife and Habitat Study designs will be discussed and coordinated with the NSB DWM for submittal to the
Protection – General NSB by March 1, 2021, and each year thereafter as necessary. The NSB DWM and
Provisions for Studies on Planning will review, seek revisions as appropriate, and approve the study designs by April
Wildlife and Subsistence 1, 2021, and each year thereafter as necessary.
7 Wildlife and Habitat An annual report will be prepared and distributed to NSB DWM and Planning departments
Protection – General by February 15 and a meeting scheduled with NSB DWM and Planning, to occur by April
Provisions for Studies on 1. This meeting will discuss the results and the potential need for adjustments to scope to
Wildlife and Subsistence assess possible impacts to caribou, waterbirds, fish, and subsistence users. The Land
Management Administrator and Director of the DWM will make the final decision of
whether study designs need to be altered and/or additional data collection or analyses are
required.
8 Wildlife and Habitat CPAI will consult with KSOP on study design prior to submittal to the NSB and provide
Protection – General KSOP with annual reports.
Provisions for Studies on
Wildlife and Subsistence
9 Wildlife and Habitat CPAI will make data available from their studies annually to the NSB DWM and within a
Protection – General year of completion of the study to the general public through a data archive (e.g.,
Provisions for Studies on University of Alaska’s Geographical Information Network of Alaska, Alaska Ocean
Wildlife and Subsistence Observing System).
10 Wildlife and Habitat CPAI will provide the DWM with reports from studies (e.g., wildlife, habitat, erosion)
Protection – General required by other agencies involved in permitting lands associated with the Willow Project,
Provisions for Studies on and to the maximum extent practical where multiple study requirements can be aligned,
Wildlife and Subsistence avoid duplication of study efforts among the NSB and such other agencies.
11 Wildlife and Habitat To the extent practicable, CPAI and its contractors will minimize flights by hiring local
Protection – General boat drivers, snow machine drivers, and allowing their contractors to camp at a study site.
12 Wildlife and Habitat To the extent practicable, CPAI will involve students from Nuiqsut (or other North Slope
Protection – General communities if no students are available from Nuiqsut) in their studies.


13 Wildlife and Habitat CPAI will fund a caribou study to analyze the distribution and movements of caribou
Protection – Caribou around the Willow Project area and adjacent areas to assess habitat relationships and
possible impacts from development. CPAI will fund a third-party contractor to:
• Characterize pre-construction caribou movements utilizing historic telemetry data
• Assist ADF&G or the NSB DWM in the collection of GPS telemetry data (e.g.,
potential purchase of additional caribou collars or database management)
• Determine caribou pre- and post-construction movement rates in relation to roads
pipelines and pads associated with their project
• Characterize habitat conditions (e.g., snow melt, vegetation habitat, plant biomass,
infrastructure) within the study area using best available technology
• Evaluate these indices of habitat conditions, with particular attention to possible
impacts from development, on the distribution of caribou utilizing the study area
14 Wildlife and Habitat CPAI will conduct a study of molting waterfowl in the vicinity of the Willow Project and
Protection – Birds farther to the west. The final study area will be determined in consultation with the DWM
and after consulting with the USFWS to determine the area that is currently being
monitored for molting geese. The study will be conducted for at least three years. After that
time, the results will be reviewed and a determination will be made about whether the
surveys need to continue and if so, for how long. The final determination will be made by
the Land Management Administrator and Director of the DWM.
15 Wildlife and Habitat CPAI will fund a third-party contractor to conduct a breeding shorebird study in and
Protection – Birds adjacent to the Willow Project area. As this is known to be important shorebird breeding
habitat, baseline studies will be conducted annually pre-development, and at least once
every three years after development has been initiated. This study will document shorebird
abundance, density, and nesting success.
16 Wildlife and Habitat CPAI will fund a third-party contractor to conduct a Yellow-billed loon study in and
Protection – Birds adjacent to the Willow Project area. To minimize impacts to breeding Yellow-billed loons,
the study will document presence and habitat use (breeding/non-breeding) through
techniques such as aerial or ground surveys but will avoid nest examination until
termination of nesting.
17 Wildlife and Habitat CPAI will fund a third-party contractor to collect baseline data to help detect possible
Protection – Fish impacts, mitigate impacts, or conduct a damage assessment in the event of oil spills and/or
release of oil-related products. Potential impacts are not restricted to population level
effects.
18 Wildlife and Habitat CPAI will repeat required predevelopment studies (baseline) outlined by BLM and
Protection – Fish USFWS every four years. Should differences be detected from baseline, then CPAI will
consult with NSB DWM on whether additional studies are required to explain differences
and/or to monitor change. If CPAI divests, sells, or significantly alters management
responsibility for the Willow Project, then CPAI is required to provide funding for another
year of those studies to incoming management to be conducted during the subsequent
summer season.
19 Wildlife and Habitat CPAI will experimentally determine the effect of sublethal hydrocarbon exposure and
Protection – Fish persistence of detection of exposure on two species of fish (fourhorn sculpin and Arctic
Cisco) and two prey items of fish, at four temperatures that reflect local seasonal changes
(summer, autumn, and spring and winter) using, Alaska North Slope Crude oil and, when
available, hydrocarbon from the Willow Project (i.e., not mixed to produce Alaska North
Slope Crude). This experimental method must be developed so that it can used to determine
whether fish and their prey items have been exposed during accidental releases of
hydrocarbons from CPAI operations. If no accidental releases occur in 10 years, then repeat
the experiment using more updated tools, methodologies, and analyses, while making sure
that previous experimental results can be used for comparison. If data are not sufficient to
fulfill this stipulation, additional studies may be required.
20 Wildlife and Habitat Fish detected with water mold or other newly emerging infections in both the Nuiqsut Fall
Protection – Fish Fishery and in areas associated with CPAI’s influence will be recorded, collected, and
reported to the NSB DWM.


21 Wildlife and Habitat CPAI will collect data on water quality and hydrology to help detect potential Project
Protection – Water Quality related impacts on fish and the subsistence fishery. CPAI will be required to repeat required
predevelopment studies (baseline) outlined by BLM and USFWS every four years. Should
differences be detected from baseline, then CPAI will consult with NSB DWM on whether
additional studies are required to explain differences and/or to monitor change. If CPAI
divests, sells, or significantly alters management responsibility for the Willow Project, then
CPAI is required to provide funding for another year of those studies to incoming
management to be conducted during the subsequent summer season.
22 Wildlife and Habitat CPAI will fund a contractor to design and conduct a subsistence study that investigates the
Protection – Subsistence effects of CPAI’s Willow Project development activities and associated infrastructure, as
well as future exploration and development activities and associated infrastructure, to
subsistence hunters from Nuiqsut. The study should focus on all of CPAI’s facilities and
activities within the area that is subject to this re-zone, as well as facilities and activities
outside of this area that have the potential to impact subsistence resources and activities
within the area, as determined by discussions with the NSB DWM and Planning staff. The
project should at a minimum:
• Examine possible effects from CPAI developments and activities to subsistence
activities, especially on caribou and migratory bird hunting
• Document hunter concerns and opinions about impacts from CPAI’s facilities and
activities associated with this rezone
23 Minimizing Traffic Impacts – CPAI shall coordinate with KSOP, Kuukpik, and the NSB DWM and Planning
General departments to establish standard air traffic routes that will minimize interference with
animal concentrations. (Concentrations of caribou herds are of particular concern.) CPAI
shall follow these routes unless there is a threat to human safety, or an animal concentration
or subsistence user is positioned along the routes.
24 Onshore Oil and Gas Siting, design, construction, and maintenance of pipelines must minimize alteration of
Pipelines and Roads – shorelines, water courses, wetlands, and tidal marshes and avoid significant disturbance to
General important habitats and critical migration periods.
25 Onshore Oil and Gas Permanent oil and gas facilities, including gravel pads, roads, airstrips, and pipelines, must
Pipelines and Roads – be consolidated to the maximum extent possible.
Consolidation
26 Onshore Oil and Gas Pipeline design and construction shall be based on the best available information and
Pipelines and Roads – include adequate pipeline elevation, ramping, or burial to provide for unimpeded wildlife
Wildlife Crossing crossing. Aboveground pipelines and all associated infrastructure (including fiber optic and
other cables) must be elevated at or above the 7-foot minimum height except at those points
where the pipeline intersects a road, pad, or caribou ramp, or is constructed within 100 feet
of an existing pipeline that is elevated less than 7 feet.
27 Onshore Oil and Gas Pipelines must be separated from roads by a minimum distance of 500 feet (except at those
Pipelines and Roads – points where the pipeline intersects a road, pad, or caribou ramp).
Placement
28 Onshore Oil and Gas Pipelines shall not be constructed at a distance greater than 1,000 feet from any access road.
Pipelines and Roads –
Placement
29 Onshore Oil and Gas Permanent oil and gas facilities, including gravel pads, roads, airstrips, and pipelines, are
Pipelines and Roads – prohibited on the lake or lakebed and within 1,500 feet of the ordinary high-water mark of
Placement any fish-bearing deep lake (i.e., depth greater than 4 meters). If the fish-bearing status of a
lake is unknown, the burden is on CPAI to demonstrate whether fish are present.
30 Onshore Oil and Gas Appropriate facilities shall be installed to ensure adequate drainage patterns.
Pipelines and Roads –
Drainage
31 Onshore Oil and Gas CPAI will monitor for sedimentation build-up or scouring resulting from all bridges and
Pipelines and Roads – provide the Administrator with results of such monitoring on a regular basis. The
Sedimentation Administrator may require measures to mitigate sedimentation and scouring, including
dredging, to ensure that the subsistence use area is maintained.
32 Economic Opportunity – Job CPAI will host a job fair annually in Nuiqsut beginning after the Assembly’s approval of
Fairs CPAI’s Application.


33 Economic Opportunity – CPAI shall submit annual reports to the Administrator by December 1st of each year
Employment Reports showing the number of NSB residents employed by CPAI by job type. Overall
employment statistics will be part of this reporting, showing the percentage of NSB
resident employment, separate for Alaska resident employment. The overall employment
report will also reflect the total workforce, by resident location, of CPAI' s workforce in
Alaska.
34 Economic Opportunity – Bids When CPAI solicits bids, it shall invite North Slope suppliers, subcontractors, and regional
and village corporations to bid on Willow projects for which they are qualified.
35 Economic Opportunity – NSB strongly urges CPAI to adopt a formal policy to avoid scheduling disruptions and
Subsistence Policy misunderstandings when subsistence leave is needed while employed by CPAI. The use of
seasonal employment options as a method of addressing subsistence leave flexibility is not
a meaningful method of employment that allows NSB residents to gain CPAI workplace
experience. This requirement should be passed onto all CPAI contractors to the maximum
extent allowable.
36 Economic Opportunity – NSB shall provide land management orientation for CPAI for its Willow projects on an
Land Management annual basis.
Orientation
37 Economic Opportunity – CPAI shall fund a year-round subsistence representative.
Subsistence Representative
38 Cultural and Historical Site CPAI must contact the NSB IHLC Division at (907) 852-0422 and SHPO to obtain a set of
Protection – Data Points for data points for sites of possible historic, prehistoric, cultural, traditional, archeological, and
Critical Sites paleontological significance (Critical Sites). CPAI will maintain the data provided by IHLC
in a secure place for internal use only and shall not disclose that data to any other person or
entity except SHPO and those entities with a need to know for the purposes of the planned
Willow and associated developments and associated facilities, including roads, bridges,
gravel pads, airstrips, and pipelines. CPAI will retain and update this data throughout the
life of the development project. Prior to the completion of the development project, CPAI
will come to an agreement with IHLC as to the disposition of IHLC data once the project is
completed. Data points provided by IHLC in the form of geographic coordinates may be
imprecise. CPAI is nevertheless responsible for ensuring that its operations do not cause
any adverse impacts to Critical Sites and for reporting to IHLC the proper coordinates of
any such site discovered. CPAI will release NSB from any liability associated with CPAI's
use of these data points.
39 Cultural and Historical Site CPAI must maintain an effective buffer zone around all sites of possible historic,
Protection – Buffer Zones prehistoric, cultural, traditional, archeological, and paleontological significance (Critical
Sites). An effective buffer zone will be at least 500 feet unless a smaller zone is necessary
and can be mutually agreed upon by CPAI and the NSB Planning Department. CPAI must
train its staff and contractors to observe this buffer and ensure that Critical Sites are not
disturbed.
40 Cultural and Historical Site Should any human remains or possible historic, prehistoric, cultural, traditional,
Protection – Discovery of archeological, and paleontological significant materials (Critical Site materials), including,
Remains or Materials but not limited to artifacts, house mounds, grave sites, ice cellars, and fossilized animal
remains, be discovered in the course of this field survey
that were not already identified by IHLC or SHPO, CPAI must stop all work in the vicinity
of the discovery until CPAI has made contact with IHLC at (907) 852-0422, SHPO and, in
the case of human remains, the Alaska State Troopers, and has obtained these agencies'
approvals to continue work. CPAI must submit any information discovered that may be of
historic, prehistoric, cultural, traditional, archeological, and paleontological significance to
IHLC (including, but not limited to artifacts, house mounds, grave sites, ice cellars, and
fossilized animal remains). CPAI must not disclose that data to any other person or entity
except SHPO and those entities with a need to know for the purposes of working on the
planned Willow and associated developments and associated facilities (including roads,
bridges, gravel pads, airstrips, and pipelines). CPAI must not remove or disturb any items
that may be of historic, prehistoric, cultural, traditional, archeological, and paleontological
significance, except to the extent needed to document their existence and to comply with
state and federal law and this ordinance.


41 Cultural and Historical Site CPAI must not trespass on Native Allotments or private property. Owner permission must
Protection – Allotments be obtained in advance to enter onto the surface of these lands. CPAI must work with the
Inupiat Community of the Arctic Slope and Native Allotment owners in and around the
area in a beneficial manner.
42 Cultural and Historical Site Upon IHLC's request, CPAI must allow an IHLC representative to accompany CPAI
Protection – Site Visits during field work. The IHLC representative shall comply with all CPAI safety and
operational rules and requirements when accompanying CPAI during field work.
43 Reclamation Plan – General An abandonment/reclamation plan must be submitted to the Administrator within three
years of cessation of permitted activities. At a minimum, the plan must contain:
• A grading and site plan drawn and certified by an Alaska licensed professional engineer
or land surveyor, indicating the areas excavated or filled, the proposed finished grades
and contours, drainage directions and any control structures to be installed.
• The methods and plans to be employed for reclamation of the site during and after the
activity shall be stated along with a timetable for completions.
• A description of all roads and structures and a site map showing the locations of all
roads and development which will be built indicating which ones will remain after
cessation of activities.
• A description of any known reclamation requirements of any other governmental entity,
and a copy of any reclamation plan under development or in existence for the activity.
• All maps shall be submitted at a scale of one inch equals 200 feet extending 200 feet
beyond the site area with a maximum contour interval of five feet. The scale
requirements may be adjusted by the Administrator to fit unusual circumstances.
44 State, Local, and Federal This approval shall not become effective until all other local, state, and federal permits,
Compliance – Other Permits approvals, and authorizations have been issued. CPAI shall comply with all local, state, and
federal laws and regulations for all projects within the Unit area.
45 Tundra Protection – General Vehicles must be operated in a manner such that the vegetative mat of the tundra is not
disturbed, and blading or removal of tundra or vegetative cover is prohibited unless
specifically approved by the NSB Land Management Administrator or his designee.
46 Tundra Protection – General Development is required to maintain the natural permafrost insulation quality of existing
soils and vegetation.
47 Tundra Protection – General Trails, campsites, and worksite must be kept clean. No littering is allowed. All solid waste
including incinerator residue must be backhauled to an authorized solid waste disposal
facility.
48 Tundra Protection – General Winter on-tundra travel may begin when six inches of snow cover and twelve inches of
frost depth conditions exist, consistent with State regulations, for the activities intended as
determined by an authorized field representative of the Administrator. Certain on-tundra
activities may begin sooner than others depending on the impact or magnitude of the
operations.
49 Tundra Protection – General After April 15 of each year, on-tundra travel must be subject to termination within 72 hours
of notification by the NSB Administrator or his/her designee for protection of surface
vegetation.
Note: ADF&G (Alaska Department of Fish and Game); BLM (Bureau of Land Management); CPAI (ConocoPhillips Alaska, Inc.); DWM
(Department of Wildlife Management); GPS (global positioning system); IHLC (department of Inupiat History, Language and Culture);
KSOP (Kuukpik Subsistence Oversight Panel); Kuukpik (Kuukpik Corporation); NSB (North Slope Borough); NVN (Native Village of
Nuiqsut); SHPO (Alaska State Historic Preservation Office); USFWS (U.S. Fish and Wildlife Service).
Table 5.3. North Slope Borough Rezoning Conditions of Approval

No. Category Condition of Approval
1 Wildlife Disturbance – CPAI will use insulation in the Willow gravel infrastructure to reduce the height (and
Gravel Infrastructure visual barrier) of these features to minimize impacts on caribou movement, subject to
obtaining necessary permits and agency authorizations. CPAI will submit a detailed
implementation plan, including explanation of where insulation is and is not practicable, to
the NSB by September 30, 2021, pursuant to NSBMC Chapter 19.50.


2 Wildlife Disturbance – CPAI will reduce the length of the Willow airstrip to a maximum 5,700 feet long. Final
Airstrip approval of the airstrip dimensions will be determined in accordance with NSBMC Chapter
19.50. CPAI has no plans to use the Willow airstrip for Boeing 737s or similar passenger
aircraft, and therefore will leave the surface of the runway as gravel. Any modification of
this condition, including the use of Boeing 737s or similar passenger aircraft, will require
approval of the NSB Assembly. The airstrip permit application will include an analysis of
required runway dimensions based on aircraft manufacturer guidance, Federal Aviation
Administration requirements and recommendations, safety considerations, and engineering
best practices.
3 Use Plans – Vehicle Plan CPAI will provide the NSB a vehicle plan that includes restrictions on, and minimization of
vehicle use, during sensitive periods (e.g., caribou calving, bird nesting, peak caribou
subsistence activity). The objective of the vehicle plan is to mitigate potential impact of
Willow project vehicle traffic on caribou calving, bird nesting, and peak subsistence
activity. A vehicle plan for construction activities beginning in 2022 will be developed in
consultation with the North Slope Borough Wildlife Department, and submitted for review
and approval, in accordance with NSBMC Chapter 19.50, no later than September 1, 2021
and updated as needed when drilling and operations commence.
4 Use Plans – Aircraft Plan CPA will provide the NSB an aircraft plan that minimizes aircraft use during sensitive time
periods (e.g., caribou calving, bird nesting, peak caribou subsistence activity) and will
include a communication protocol with the local community. The
objective of the aircraft plan is to mitigate potential impact of Willow project air traffic on
caribou calving, bird nesting, and peak subsistence activity. An aircraft plan will be
developed in consultation with the NSB Wildlife Department and submitted for review and
approval, in accordance with NSBMC Chapter 19.50, at least six months prior to the
Willow airstrip commissioning.
5 Use Plans – Diesel Use Plan CPAI will submit a diesel use plan for review and approval, in accordance with NSBMC
Chapter 19.50, by October 31, 2021. The plan will include an analysis of diesel
transportation, including the conversion of existing pipelines or the utilization of Willow
pipelines authorized in the Willow Master Development Plan Environmental Impact
Statement Record of Decision for diesel transportation. The objective of this plan is to
minimize traffic impacts and spill impacts due to human error on roads in high-use
subsistence areas.
6 Subsistence – Good Neighbor During the construction period of the Willow Project (prior to start-up of the central
Policy processing facility), if requested by the NSB Subsistence Mitigation Committee, in addition
to the existing contributions, CPAI will provide an annual air charter for a group of Nuiqsut
hunters and their gear to support caribou subsistence activities. This will be requested and
administered by the NSB’s Subsistence Mitigation Committee.
CPAI will develop a Good Neighbor Policy on caribou in consultation with the community
of Nuiqsut and the NSB Wildlife and Planning Departments. CPAI will host at least one
community workshop in the Village of Nuiqsut to obtain input from hunters and residents
prior to October 31,2021. The Good Neighbor Policy will include support to transport
Nuiqsut caribou subsistence hunters and their gear to and from areas where caribou are
available if it is determined that the Willow Project has significantly impacted the ability of
the hunters to harvest caribou based on criteria in the Good Neighbor Policy. The
determination will be made by the Director of the North Slope Borough Planning
Department, in consultation with the North Slope Borough Wildlife Department. CPAI will
submit a Good Neighbor Policy to the North Slope Borough on or before June 30,2022 for
review and approval, in accordance with NSBMC Chapter 19.50.


7 Mitigation – Mitigation Fund CPAI will amend Section 1(b) of the Oil Spill Mitigation Fund Agreement for the Alpine
Agreement Amendments Development District (executed August 2019) (“Agreement”), to incorporate the Willow
Development District into the Agreement, with an effective date prior to Willow first oil.
The Agreement will also be amended to include spills to land. To accomplish that, Section
2(a)(i) of the Agreement will be deleted in its entirety and replaced with the following:
"CPAI's oil and gas activities in the Alpine or Willow Development Districts cause oil to be
present on land or in the water, or on the ice over water." CPAI will submit this amendment
for NSB review and approval, in accordance with NSBMC Chapter 19.50, six months prior
to anticipated Willow first oil.
Note: CPAI (ConocoPhillips Alaska, Inc.); NSB (North Slope Borough); NSBMC (North Slope Borough Municipal Code).

6.0 PROPONENT’S ADDITIONAL MITIGATION MEASURES

CPAI also provides additional mitigation to offset impacts from all CPAI developments in the Nuiqsut area (not
the Willow Project alone). These efforts, while not required by the BLM under this Decision, serve to mitigate
impacts from oil and gas development on the North Slope. These efforts are summarized below:
• Providing the City of Nuiqsut access to a grant writer to assist with grant proposals, which could increase
the local understanding that mitigation funds are available and decrease some concerns over the impacts
of the Project.
• Providing funding for accounting support, which is critical to successfully managing grant money.
• Continuing to provide resources, access, or services from CPAI North Slope developments to residents of
Nuiqsut through the CPAI outreach program. The program includes:
o Providing annual grants to support the Alaska Eskimo Whaling Commission (though this does not
provide a direct benefit to Nuiqsut residents, the Nuiqsut Whaling Captains Association is affiliated
with the Alaska Eskimo Whaling Commission, along with the other 10 Alaskan whaling
communities)
o Providing education and workforce development programs (Nuiqsut Trapper School, Ilisaġvik
College, scholarship funds, and more)
o Funding community projects (such as the Elder’s Housing Project, Nuiqsut playground, outdoor
basketball court, and early learning center)
o Making donations to the community (including fire trucks, spill response boats, supplies for the teen
center, etc.)
o Providing emergency response assistance to the community of Nuiqsut
• Assisting the City of Nuiqsut with the design and construction of a Colville River boat launch.
• Engaging with the Nuiqsut search and rescue group to identify opportunities for CPAI to support them
with equipment needs or equipment staging. CPAI will continue to support the Nuiqsut Community
Development Foundation which supports the City of Nuiqsut in obtaining and managing grants for
community needs, such as search and rescue.
• Providing natural gas to the community of Nuiqsut (per agreement with Kuukpik Corporation).
• Providing funds to support administration of the Kuukpik Subsistence Oversight Panel (per agreement
with Kuukpik Corporation).
• Funding of scholarships via the Kuukpikmiut Foundation (per agreement with Kuukpik Corporation). 4
4
The project proponent may also add to these measures a relinquishment of leases within the northern and southern areas of
the Bear Tooth Unit that are not targeted by the approved drill sites (BT1, BT2 and BT3). The Proponent may request to
relinquish those leases to conform the Bear Tooth Unit to this Decision. The BLM would work through standard procedures
to process and approve any such request.

7.0 REFERENCES
ADF&G. 2002. Aquatic Nuisance Species Management Plan. Juneau, AK: ADF&G, Aquatic Nuisance Species
Task Force.
ADOT&PF. 2006. Alaska Highway Drainage Manual.
BLM. 2013. National Petroleum Reserve-Alaska Integrated Activity Plan/Environmental Impact Statement Record
of Decision. Anchorage, AK.
-----. 2022a. National Petroleum Reserve-Alaska Integrated Activity Plan/Record of Decision. Anchorage, AK.
-----. 2022b. BLM response to NMFS regarding proposed mitigation measures.
European Environment Agency. 2011. Forests, Health and Climate Change.

https://www.eea.europa.eu/articles/forests-health-and-climate-change.
Lawhead, B.E., J.P. Parrett, A.K. Prichard, and D.A. Yokel. 2006. A Literature Review and Synthesis on the Effect
of Pipeline Height on Caribou Crossing Success. Open-File Report 106. Fairbanks, AK: BLM.
Lawhead, B.E., A.K. Prichard, M.J. Macander, and M. Emers. 2004. Caribou Mitigation Monitoring Study for the
Meltwater Project, 2003: Third Annual Report. Anchorage, AK: Prepared by ABR, Inc. for
ConocoPhillips Alaska, Inc.
Limpinsel, D.E., M.P. Eagleton, and J.L. Hanson. 2017. Impacts to Essential Fish Habitat from Non-Fishing
Activities in Alaska: EFH 5-Year Review, 2010 through 2015. NOAA Technical Memorandum NMFS-
F/AKR-14. Anchorage, AK: NMFS.
NMFS. 2022. Essential Fish Habitat correspondence to BLM regarding mitigation measures.
-----. 2023. Willow Master Development Plan Letter of Concurrence.
UNFCCC. 2021. The United States of America Nationally Determined Contribution. Reducing Greenhouse Gases
in the United States: A 2030 Emissions Target.
USACE. 1986. Accuracy of Computed Water Surface Profiles. Davis, CA: Prepared by USACE Hydrologic
Engineering Center for Federal Highway Administration.
USFS. 2021. Budget Justification: FY 2022. U.S. Department of Agriculture.
USFWS. 2023. U.S. Fish and Wildlife Service Final Willow Master Development Plan Biological Opinion.
Yokel, D., D. Huebner, R. Meyers, D.A. Nigro, and J.M. Ver Hoef. 2007. Offsetting Versus Overlapping Ice Road
Routes from Year to Year: Impacts to Tundra Vegetation. Anchorage, AK: BLM.

Record of Decision

Appendix B
Alaska National Interest Lands Conservation Act Section
810 Compliance
March 2023
Table of Contents
1.0 Alaska National Interest Lands Conservation Act Section 810 Compliance ................................... 1
1.1 Significant restriction of subsistence use is necessary, consistent with sound
management principles for the utilization of public lands ........................................................ 1
1.2 The proposed activity will involve the minimal amount of public lands necessary to
accomplish the purpose of such use, occupancy, or other disposition ...................................... 2
1.3 Reasonable steps will be taken to minimize adverse impacts upon subsistence uses and
resources resulting from such actions........................................................................................ 3
2.0 References ........................................................................................................................................ 5
List of Acronyms
ANILCA Alaska National Interest Lands Conservation Act
Decision Record of Decision
GMT-2 Greater Mooses Tooth 2
IAP Integrated Activity Plan
ROP required operating procedure
TLSA Teshekpuk Lake Special Area
Appendix B ANILCA Section 810 Compliance Page i

Appendix B ANILCA Section 810 Compliance Page ii

1.0 ALASKA NATIONAL INTEREST LANDS

CONSERVATION ACT SECTION 810 COMPLIANCE
The Alaska National Interest Lands Conservation Act (ANILCA) Section 810 provides that no public
land uses which would significantly restrict subsistence uses shall be effected until the federal agency
gives the required notice and holds a hearing in accordance with ANILCA Section 810(a)(1) and (2) and
makes the three determinations required by ANILCA Section 810(a)(3)(A), (B), and (C). The three
determinations that must be made are:
1. That such a significant restriction of subsistence use is necessary, consistent with sound
management principles for the utilization of public lands;
2. That the proposed activity will involve the minimal amount of public lands necessary to
accomplish the purposes of such use, occupancy, or other such disposition; and
3. That reasonable steps will be taken to minimize adverse impacts upon subsistence uses and
resources resulting from such action.
The ANILCA Section 810 analysis and findings for the Willow Master Development Plan (MDP) Project
(Project) are included in Final Supplemental Environmental Impact Statement (EIS) Appendix G, Alaska
National Interest Lands Conservation Act Section 810 Analysis, and are summarized in the following
paragraph with respect to Alternative E and Module Delivery Option 3 as described in the Final
Supplemental EIS.
The Bureau of Land Management’s (BLM) findings conclude that the Project is not expected to result in a
large reduction in the abundance (population level) of caribou or any other subsistence resource.
However, the evaluation concludes that under Alternative E (and the other action alternatives) the Project
may significantly restrict subsistence uses for the community of Nuiqsut due to a reduction in the
availability of caribou and furbearers caused by the alteration of their distribution and limitations on
subsistence user access in or near the Project area. Module Delivery Option 3, in combination with
Alternative E, would not result in any additional significant restriction of subsistence uses for
communities in or near the Project area. BLM’s findings conclude that the Project, when considered along
with the cumulative effects of current and future activities, may also significantly restrict subsistence uses
for Nuiqsut due to a reduction in availability of caribou and furbearers caused by the alteration of their
distribution and limitations on subsistence user access in or near the Project area.
Consistent with ANILCA Section 810 (a)(1) and (2), and in light of the positive “may significantly
restrict subsistence uses” findings described above, BLM undertook notice and hearing procedures in
conjunction with the release of the Willow MDP Draft Supplemental EIS in order to solicit public
comment from the potentially affected community of Nuiqsut. Input from the subsistence hearing
conducted in Nuiqsut was incorporated into the final ANILCA Section 810 evaluation; however, no
alterations were made to the final findings.
Because the final ANILCA Section 810 evaluation concludes that Alternative E and Module Delivery
Option 3 as described in the Final Supplemental EIS may significantly restrict subsistence uses, including
in the cumulative case, BLM is required to make the three determinations required by ANILCA Section
810(a)(3)(A), (B), and (C) found in this Appendix. These determinations incorporate this Decision’s
disapproval of drill site BT5 in lieu of its deferral, as well as the disapproval of drill site BT4.
1.1 Significant restriction of subsistence use is necessary, consistent with

sound management principles for the utilization of public lands
BLM has prepared the Willow MDP Supplemental EIS in response to the United States District Court of
Alaska’s 2021 decision remanding the Willow MDP EIS to BLM for the purpose of addressing National
Environmental Policy Act deficiencies in its analysis of ConocoPhillips Alaska, Inc.’s proposal to
construct infrastructure necessary to allow the production and transportation to market of federal oil and
Appendix B ANILCA Section 810 Compliance Page 1

as resources in the Willow reservoir located in the Bear Tooth Unit in the northeast area of the National
Petroleum Reserve in Alaska (NPR-A).
In its preparation of the Willow MDP Supplemental EIS, BLM considered and balanced a variety of
factors in its development of Project alternatives and analysis of proposed Project activities on public
lands. Prominent in its considerations were comments received during public scoping and comment
periods and hearings that emphasized the importance of protecting caribou movement and migration and
reducing the effects of industrial development on subsistence use and the traditional ways of life of the
community of Nuiqsut. In recognition of these comments and consistent with the United States District
Court’s direction to consider alternatives that provide “maximum protection” for surface values in the
Teshekpuk Lake Special Area (TLSA) in accordance with the BLM’s statutory directives, BLM added a
fourth action alternative (Alternative E), which reduces infrastructure within the TLSA relative to the
previously analyzed action alternatives.
BLM has determined that Alternative E as modified and approved in this Decision [BT1, BT2 and BT3
approved; BT5 disapproved] combined with Module Delivery Option 3 (Colville River Crossing) best
fulfills the purpose and need of the proposed action while also incorporating protective measures and
Project features to reduce impacts to important subsistence uses and resources. By substantially reducing
the overall amount of infrastructure, including in the TLSA, Alternative E reduces potential impediments
to caribou movement and subsistence users. The construction of up to three new subsistence use boat
ramps will help mitigate the impact of the proposed action on subsistence uses and resources by providing
additional access points to important subsistence use areas. Additionally, the lease stipulations (LSs) and
required operating procedures (ROPs) established by the 2022 NPR-A Integrated Activity Plan (IAP)/EIS
Record of Decision (Decision or ROD) (BLM 2022) that apply to the alternative, combined with the
additional mitigation measures adopted in Section 3.0 of Appendix A of this ROD will minimize the
impact of the proposed action on subsistence uses and resources.
BLM has determined that the significant restrictions that may occur under Alternative E as modified and
approved in this Decision [BT1, BT2 and BT3 approved; BT5 disapproved], in combination with Module
Delivery Option 3, when considered together with all the possible impacts of the action, including the
cumulative case, are necessary and consistent with sound management principles for the use of these
public lands and BLM’s obligations as established under the statutory directives in the Naval Petroleum
Reserves Production Act, as amended, the Federal Land Policy and Management Act, and other
applicable laws.
1.2 The proposed activity will involve the minimal amount of public lands
necessary to accomplish the purpose of such use, occupancy, or other
disposition
BLM analyzed a range of alternatives, including a No Action alternative (Alternative A) and four action
alternatives (B, C, D, and E) and three module delivery options (1, 2, and 3) which met the purpose and
need of the proposed action. The range of alternatives was developed by resource specialists from BLM
and cooperating agencies, and from comments received during scoping, including those concerning
potential impacts to subsistence uses and resources.
While Alternative A, the No Action Alterative, would involve the least amount of public lands, it would
not accomplish the purpose and need of the proposed action. As such, BLM has determined that
Alternative E as approved in this Decision [BT1, BT2 and BT3 approved; BT5 disapproved], combined
with Module Delivery Option 3, involves the minimal amount of public lands necessary to fulfill the
purpose and need of the proposed action. As modified and approved in this Decision, Alternative E
includes three drill sites (BT1, BT2, and BT3), the Willow Processing Facility (WPF) and Willow
Operations Center, an all-season gravel road connection extending from the Greater Mooses Tooth 2
(GMT-2) drill site southwest to the WPF, an airstrip, infield and export pipelines, and gravel roads
(including five turnouts with subsistence/tundra access ramps and five bridges) connecting the three drill
sites to the WPF. Gravel roads would cross Judy (Iqalliqpik), Judy (Kayyaaq), and Fish creeks.

In addition to Project infrastructure, the Proponent would also construct up to three boat ramps for
subsistence uses. One of the boat ramps (common to all action alternatives) would provide access to the
Ublutuoch (Tiŋmiaqsiuġvik) River along the existing gravel road between Alpine drill site CD5 and the
Greater Mooses Tooth 1 drill site. Up to two additional boat ramps would be constructed along Judy
(Iqalliqpik) Creek and/or Fish Creek pending further community input. All three boat ramps would be
accessed via short roads connected to Project roads near Project bridges. During construction, the Project
would also develop the Tiŋmiaqsiuġvik gravel mine site, with two distinct mine site pits.
Under Module Delivery Option 3, large sealift modules (weighing between 3,000 and 4,000 tons) would
be received at the Oliktok Dock and transported over the existing gravel road network in Kuparuk south
to existing drill site DS2P. From DS2P, the modules would be transported via a task-specific ice road
across the Colville River (near Ocean Point) to the Project area near the GMT-2 drill site. From GMT-2,
the modules would be transported over Project gravel roads to their installation location. Alternative E,
combined with Module Delivery Option 3, as approved in this Decision (BT1, BT2 and BT3 approved;
BT5 disapproved), would have a total footprint of approximately 499 acres (384 acres of gravel footprint
and 115.0 acres of excavation). This is less than any of the other action alternatives.
All Project activities were developed in accordance with the 2022 NPR-A IAP ROD and Section 404 of
the Clean Water Act, which all require lessees to minimize facility footprints and propose siting and
alignment of facilities in such a manner as to minimize environmental impacts to various resources (e.g.,
caribou, wetlands).
1.3 Reasonable steps will be taken to minimize adverse impacts upon

subsistence uses and resources resulting from such actions
BLM used information acquired through analysis of impacts to subsistence, insight from public meetings
and ANILCA Section 810 hearings, and consultation with tribal and local governments to inform its
selection of a modified Alternative E in this Decision. This Decision adopts Alternative E but in doing so
further reduces impacts to subsistence uses by disapproving drill site BT5, as well as drill site BT4
(analyzed in Alternatives B, C, and D), and includes protective measures in the form of LSs, ROPs,
Project design measures, and additional adopted mitigation measures which serve to reduce or minimize
adverse impacts to subsistence uses. The full suite of protective measures applicable to the approved
project is detailed in Appendix A of this ROD.
Existing measures as established by the 2022 NPR-A IAP/EIS ROD that would help minimize adverse
impacts to subsistence resource availability and abundance, as well as subsistence use areas, and
subsistence access associated with the construction, drilling, and operation of oil and gas facilities include
ROPs A-11, E-1, E-3, E-7, F-4, H-1, and H-3 and Lease Stipulation K-1.
Specific Project design measures that would help minimize impacts to subsistence uses include Design
Measures 68, 69, 72, and 112. As applied to Alternative E as adopted by this Decision, Design Measure
112 includes the construction of up to three subsistence boat ramps to provide local residents with
improved river access. Locations would include the Ublutuoch (Tiŋmiaqsiuġvik) River near the existing
GMT-1 access road, Judy (Kayyaaq) Creek at the proposed Willow BT1 access road crossing, and Fish
Creek at the proposed access road crossing (BT2 under Alternative E).
Additional mitigation measures adopted in this Decision that would help minimize impacts to subsistence
uses include Measures 1, 2, 11, 13, 15, 16, 17, 18, 21, and 24, 26, and 27. These measures were informed
by input from BLM specialists, cooperating agencies, tribal and local governments, and other key
stakeholders collected during the Willow MDP Supplemental EIS informal public scoping period and
public comment period.
Although not required by BLM or adopted as part of this Decision, the North Slope Borough included
both required stipulations and mitigation measures and conditions of approval as part of the North Slope
Borough’s rezoning process. Of these, Mitigation Measures 2, 3, 4, 5, 13, 22, 23, and 37 and Conditions
of Approval 1, 3, 4, and 6 would help minimize adverse impacts to subsistence resource availability and

abundance, as well as subsistence use areas, and subsistence access associated with the construction,
drilling, and operation of oil and gas facilities.
Additionally, this Decision’s disapproval of drill sites BT4 and BT5 further reduces impacts to
subsistence resources and uses, including in the sensitive TLSA. Elimination of these drill sites and their
associated road and pipeline segments will substantially reduce impacts to subsistence resources and uses,
including impediments to caribou movement and subsistence user access that are the basis of the positive
“may significantly restrict subsistence uses” finding made in Appendix G of the Final Supplemental EIS.
Given these numerous protective measures that would apply to the Project under this Decision to reduce
subsistence impacts, BLM determines that reasonable steps will be taken to minimize adverse impacts to
subsistence uses and resources from the action approved in this Decision.

2.0 REFERENCES
BLM. 2022. National Petroleum Reserve in Alaska Integrated Activity Plan/Record of Decision.
Anchorage, AK.


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U.S.

Department of the Interior

Willow Master Development Plan

Willow Master Development Plan

Bureau of Land Management

PROPONENT ConocoPhillips Alaska, Inc.

APPLICATION REFERENCE NUMBER BLM Case File FF097428

RESPONSIBLE OFFICIAL Tommy P. Beaudreau

FOR INFORMATION CONTACT Steven M. Cohn

3.0 PROJECT DESCRIPTION

3.2 Project Location

INSET B Willow Proposed Development Features

Site Standards. This product was developed through

digital means and may be updated without

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4.1 Alternatives Considered and Carried Forward for Detailed Analysis in

4.2 Rationale for Decision Adopting Alternative E as modified [BT1, BT2

Table 1. Summary of Rationale for Selected Alternative and Option

Project Component Rationale for Selection

5.0 PUBLIC INVOLVEMENT

5.1 Public Notices

5.2 Previous Public Involvement

5.3 Public Involvement for the Supplemental EIS

5.4 Evaluation and Consideration of Comments Received

5.4.1 Comments Received Prior to the Final Supplemental EIS

5.4.2 Comments Received After the Final Supplemental EIS

5.5 Engagement with Environmental Justice Communities

6.0 RELATED LAWS AND POLICIES

6.2 Endangered Species Act

6.3 Clean Air Act

6.4 Clean Water Act

6.5 Coastal Zone Management Act

6.6 Fish and Wildlife Coordination Act

6.7 Materials Act

6.8 Magnuson-Stevens Fishery Conservation and Management Act

6.9 Mineral Leasing Act

6.10 National Historic Preservation Act

6.11 Executive Order 11988 (Floodplain Management)

6.12 Executive Order 11990 (Wetlands)

6.13 Executive Order 13112 (Invasive Species)

6.14 Executive Order 12898 (Environmental Justice)

• Using a non-reflective finish on all pipelines

6.15 Executive Order 13175 (Consultation and Coordination with Indian

7.0 OTHER AUTHORIZATIONS

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8.0 FINAL AGENCY ACTION

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8.2 Departmental Approval

Digitally signed by TOMMY

Tommy P. Beaudreau Date

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Willow Master Development Plan

Appendix A Mitigation Measures Page i

Appendix A Mitigation Measures Page ii

Appendix A Mitigation Measures Page iii

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Appendix A Mitigation Measures Page iv

1.0 APPLICABLE LEASE STIPULATIONS, REQUIRED

LSs: K-1, K-2, K-4, K-5, K-6, K-12

ROPs: C-5, D-1, H-2

LSs: K-3, K-8, K-9, K-10, K-11

Source: BLM 2022a

1.2 Exceptions to Lease Stipulations and Required Operating Procedures