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Image Project Order File Cover Page XHVZE This page identifies those items that were not scanned during the initial production scanning phase. They are available in the original file, may be scanned during a special rescan activity or are viewable by directtti~~nspection of the file. v~- Order File Identifier Organizing (done) RESCAN ^ Color Items: ^ Greyscale Items: ^ Poor Quali#y Originals: ^ Other: ..o.,ded iuumiiiiuiuu DIGITAL DATA ^ Diskettes, No. ^ Other, No/Type: ae,~„~~enea uumiiuiuui OVERSIZED (Scannable) ^ Maps: ^ Other Items Scannable by a Large Scanner OVERSIZED (Non-Scannable) ^ Logs of various kinds: NOTES: BY: / Maria Date: Project Proofing BY: Maria Date: Scanning Prep-ar~ation BY: M/ aria ~, o,~e,_ V~~ 5iiii~h~~uiauiu w~P _/ •/ - x 30 = + =TOTAL PAGES . ~/~~ f/ © (Count does not include cover sheet) ~/~ / /s/ Y ll Date ~ i ~ --- Production Scanning III IIIII IIIII II III Stage 1 Page Count from Scanned File: (Count does include cover s eet) Page Count Matches Number in Scanning Pre aration: V YES N O BY: Maria Date: [-~- p~7 ~~Q lsl fff ~, Stage 1 If NO in stage 1, page(s) discrepancies were found: YES NO BY: Maria Date: /s/ Scanning is complete at this point unless rescanning is required. III II iIII III II IIIII ReScanned NI IIIIIIIIIII IIIII BY: Maria Date: /s/ Comments about this file: Quality Checked III IIIII III IIII ICI 3~ 10/62005 Orders File Cover Page.doc Other #14 Petition of Greenpeace, Inc. 1. 2. 3. March 28, 2001 Appeal of the decision to approve we1120-029- 23005-00 BPXA Apri19, 2001 Order granting rehearing May 9, 2001 Order denying rehearing Other Order #14 • ~ STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 W 7th Ave., Suite 100 . Anchorage, Alaska 99501 Petition of Greenpeace, Inc., ) for Rehearing of Approval of Permit to Drill No. 201-041) (API No. 50-029-23005-00) (Northstar Unit 29) ) May 9, 2001 ORDER DENYING REHEARING In its Order Granting Rehearing for Limited Purpose and Denying Request for Stay, the Commission stated that it would first consider whether Greenpeace, Inc. ("Greenpeace") has the right to apply for rehearing of the Commission's approval of an application for a permit to drill and would then proceed accordingly. The Commission stated that it would base its determination on any briefmg filed by Greenpeace and BP Exploration (Alaska) Inc. ("BP") in the similar matter of Permit to Drill No. 200-211 and on any supplemental briefmg filed here. (No supplemental briefmg was filed.) Having now considered the briefs of Greenpeace and BP, the Commission declines to rule on what might be called the "standing" issue but instead denies rehearing on the merits. Because the petitions and the issues in this matter and in the matters of Permit to Drill No. 200- 211 and Permit to Drill No. 201-027 are identical in almost all material respects, the Commission's decision here is based on the reasons set out in the attached Order Denying Rehearing in the matter of Permit to Drill No. 200-211 and the attached Order Denying Rehearing in the matter of Permit to Drill No. 201-027, as supplemented by the following. ACMP, EIS, Permitting, and UIC Anal~s One of the claims Greenpeace made regarding Permit to Drill Nos. 200-211 and 201-027 concerns compliance with the Alaska Coastal Management Program ("RCMP"). Greenpeace repeats that claim here but also separately asserts that the Commission has permitted wells to be drilled "that have not been analyzed as part of the RCMP ...process." In its previous orders the Commission pointed out that drilling wells under the Northstar Development Project has already been found to be consistent with the ACMP and that no further ACMP review is required. Greenpeace's additional assertion here merely repeats its earlier allegation in different words and is fully addressed by the Commission's order in Permit to Drill No. 200-211. Greenpeace also asserts that the wells "have not been analyzed as part of the ...EIS process." As a factual matter an environmental impact statement on the Northstar Development Project was prepared by federal agencies, but that is beside the point. The Commission has no authority to deny a permit to drill on the ground that the proposed well has not been analyzed as part of an EIS process. Nor may a permit to drill be denied for lack of what Greenpeace vaguely terms "appropriate federal and state permitting analysis," as long as the requirements of AS 31.05.090 have been met. Greenpeace further asserts that the Commission has permitted wells to be drilled "with no .. . UIC analysis." This presumably refers to the underground injection control program implemented through 20 AAC 25.402 and related regulatory provisions. L`nder 20 AAC 25.402, Commission ORDER DENYING REHEARING Page 1 of 2 authorization to inject fluid must be obtained before injection occurs, not before a well is drilled. There is no requirement fora "UIC analysis" in order to obtain a permit to drill. II. Public Comment on "Spare Well" Finally, Greenpeace states: "There has been no ability of the public to comment on NS 29 because it was noted as a spare well." The Commission does not understand the reference to "spare well," but such designation is immaterial in any event, because the same review and approval process applies to all permits to drill, and in no case does that process include public notice and comment prior to permit issuance. This issue was addressed at length in the Commission's order in Permit to Drill No. 200-211, where the Commission concluded that the legislature did not intend the issuance of permits to drill under AS 31.05.090 to be subject to advance notice to members of the public. NOW THEREFORE IT IS ORDERED: The petition for rehearing is DENIED. DONE at Anchorage, Alaska, this 9th day of May 2001. `~ ~ I 1 ~`" ~, ~ ~ ~ ~.. ' g NW.:. . ~'y~\'~' ~ ~ (~ Q ~ , . , .'. f. vTT ('S ~, '",,,,_ ~` ~ ~, ~~ ~~' ~ i ' ~ I certify that on May 9, 2001, a copy of the above was mailed to each of the following at their addresses of record: Cammy Oech Taylor, Chair sion Daniel T. Seamount, Jr., Commissioner Alaska Oil and Gas Conservation Commission d"~(.~.~.-~ ~Vt , W-e~.c~~ Julie M. Heusser, Commissioner Alaska Oil and Gas Conservation Commission Nancy S. Wainwright BP Attorneys Jeff Feldm Sus Orlansky Jody o m e, E c tive Secretary This decision is the final order of the Alaska Oil and Gas Conservation Commission. Any Appeal to Superior Court must be brought within 30 days from the date that this decision is mailed or otherwise distributed. ORDER DENYING REHEARING Page 2 of 2 Northstar Consistency A~is 30 Attachment B February 4, 1999 NSBCMP Policy 2.4.4. Required Features for Applicable Development NSBCMP Policy 2.4.4. (a) Vehicles, vessels, and aircraft that are likely to cause significant disturbance must avoid areas where species that are sensitive to noise or movement are concentrated at times when such species are concentrated. Concentrations may be seasonal or year-round and may be due to behavior (e.g., docks or herds) or limited habitat (e.g., polar bear denning, seal haul-outs). Horizontal and vertical bu, fJers will be required where appropriate. Concern for human safety wilt be given special consideration when applying this policy. Several stipulations will ensure the project complies with this enforceable policy. Stipulations 118 and 119 require avoidance of grizzly and polar bear dens. Stipulation 87 allows the DNR Commissioner to restrict activities within the leasehold where threatened or endangered species are found. Stipulation 88 requires maintenance of the pipeline system to avoid significant alteration of caribou migration. Stipulations 126 and 146 ensure protection of species sensitive to noise by establishing vertical and horizontal buffers for aircraft. Stipulation 124 requires noise monitoring for island activities that may affect marine species.. Lastly, Stipulation 125 requires consultation with the Alaska Eskimo Whaling Commission (AEWC), the North Slope Borough and potentially affected communities regarding activities that could affect bowhead whales or whaling. BPXA has reached an agreement in principle for a conflict avoidance agreement with the AEWC. NSBCMP Policy 2.4.4. (b) Offshore structures must be able to withstand geophysical hazards and forces which may occur while at the drill site. Design criteria must be based on actual measurements or conservative estimates of geophysical forces. In addition, structures must have monitoring programs and safety systems capable of securing wells in case unexpected geophti~sical hazards or forces are encountered. The island and pipeline have been designed to withstand geophysical forces of ice override, ice gouging, strudel scour, and erosion. The discussion in this document under the state ACMP Geophysical Hazard Areas standard provides a more detailed discussion on this issue. ~4~p~rdix l~ Northstar Consistency is 31 ~ February 4, 1999 Attachment B NSBCMP. Policy 2.4.4. (c) Development resulting in water or airborne emissions must comply with all state and federal regulations. This enforceable policy reminds the applicant that the project must meet state and federal regulations. The State of Alaska will issue permits that will ensure the applicant meets state regulations. A further discussion of air and water quality issues may be found under the state ACMP Air, Land and Water Quality standard earlier in this document... NSBCMP Policy 2.4.4. (d) Industrial and commercial development must be served by solid waste disposal facilities which meet state and federal regulations. Stipulation 18 requires BPXA to maintain a contract with a local refuse company and ensure that non-injectable solid waste is disposed of at a permitted solid waste disposal facility. Such a facility would need to meet state and federal regulations before receiving a permit. Stipulations 107 and 131 also require solid waste be backhauled to an approved solid waste disposal site. NSBCMP Policy 2.4.4. (e) Development not on a central sewage system is required to impound and process effluent to state and federal quality standards. Sewage effluent is addressed in the Environmental Protection Agency's NPDES permit and in the state's 401 certification of that permit. Stipulations 1 and 2 provide specific requirements to ensure that the effluent will meet state and federal water quality standards. Stipulations 5, 6, 7, 9, 10, 11, 12, 13, and 14 will ensure that proper monitoring and reporting takes place and that the applicant meets best management practices and has an adequate pollution prevention plan. NSBCMP Policy 2.4.4 (~ Plans for offshore drilling activities are required to include a relief well drilling plan and an emergency countermeasure plan. The relief well drilling plan must identify suitable alternative drilling rigs and their location; identify alternative relief well drilling sites; identify support equipment and supplies including muds; casing, and gravel supplies which could be used in an emergency; and specify the estimated time required to commence drilling and complete a relief well. The emergency countermeasures plan must identify the steps which will be taken to protect human life and minimize environmental damage in the event of 1) loss of a Northstar Consistency ~sis 32 ~ February 4, 1999 Attachment B drilling rig; 2) ice override; or 3) loss or disablement of support craft or other transportation systems.. BPXA submitted a relief well drilling plan with the C-Plan, and this plan has been. reviewed by the North Slope Borough. The company submitted an emergency countermeasures plan on November 6, 1998 to the North Slope Borough. Stipulation 127 requires that emergency transport be available to evacuate 100percent of the number of occupants of Seal Island at all times. NSBCMP Policy 2.4.4 (~ -~ Offshore drilling operations and o, f~`shore petroleum storage and transportation facilities are required to have an oil spill control and clean-up plan. The plan must contain a risk analysis indicating where oil spills are likely to flow under various sets of local meteorological or oceanographic conditions. Impact areas must be identified and strategies fully developed to protect environmentally sensitive areas; the spill control and clean-up equipment which is available to the operator and the response time required to deploy this equipment under the various scenarios must be contoined in the risk analysis. Intent.• Policies 2.4.4. (~) and 2.4.4. (~ are not intended to establish new regulations for offshore facilities. They restate and highlight requirements of existing regulations. Industry will not be required to go to considerable additional effort as a result of these policies. BPXA submitted an Oil Spill Prevention and Discharge Contingency Plan (C-Plan) to the Department of Environmental Conservation on July 1, 1998. Through a process of requesting additional information, the company worked with the Department of Environmental Conservation to ensure that the agency had adequate information to make a decision. The Alaska Clean Seas Technical Manual, which will be a component of the Northstar and other North Slope C-Plans, will be updated no later than 60 days after the final approval of the Northstar C-Plan. The state is requiring that BPXA meet the conditions in stipulations 137 - 145 as pan of the C-Plan approval. Attachment C of the Consistency Determination for the Northstar Project provides a detailed response to comments related to the C-Plan. NSBCMP Policy 2.4.4. (h) Offshore oil transport systems (e.g., pipelines) must be specially designed to withstand geophysical hazards, specifically sea ice. As discussed under the state ACMP Geophysical Hazard Areas standard earlier in this document, the pipeline has been designed, to withstand expected geophysical hazards • s STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMIVIISSION 333 W. 7th Ave., Suite 100 Anchorage, Alaska 99501-3539 Re: THE- PETITION OF GREENPEACE, ) INC., for Rehearing of Approval of ) Permit to Drill No. 200-211 (API No. ) 50-029-22996-00). ) May 9, 2001 ORDER DENYING REHEARING In its Order Granting Rehearing for Limited Purpose and Denying Request for Stay, the Commission afforded Greenpeace, Inc. ("Greenpeace") and BP Exploration (Alaska) Inc. ("BP") the opportunity to brief the question of whether Greenpeace has the right to apply for rehearing of the Commission's approval of an application for a permit to drill. The Commission noted that after consideration of the arguments presented by Greenpeace and BP on that issue, "the Commission will determine whether it may hear Greenpeace's petition on the merits and will proceed accordingly." Having now considered the briefs filed by Greenpeace and BP in this matter, the Commission declines to rule on what might be called this "standing" issue but instead denies rehearing on the merits. I. Is Greenpeace a "Person Affected" under AS 31.05.080(a)? AS 31.05.080(a) provides, in relevant part:. Within 20 days after written notice of the entry of an order or decision of the commission ... a person affected by it may file with the commission an application for the rehearing in respect of the matter determined by the order or decision, setting forth the respect in which the order or decision is believed to be erroneous. (Emphasis supplied.) Greenpeace asserts that it is affected by the challenged permit approval because of its interest in use of public. resources such as fish, wildlife, marine mammals, and water that may be harmed from a well blowout, aquifer contamination, drilling mud spills, or other failures. In addition, a Greenpeace member asserts that his "navigational, scientific, recreational and aesthetic use of the area [in the vicinity of the Northstar project] is currently, and was, adversely affected by Northstar oil and gas activities that blocked [his] access to navigable waters, and impaired [his] ability to engage in the activities, or to use public resources." As a preliminary observation, Greenpeace appears to have an exaggerated notion of the legal criteria that guide the approval or disapproval of an application for a permit to drill. Under AS 31.05.090, the issuance of a permit to drill is mandatory unless "the drilling of the well is contrary to law or a regulation or order of the commission, or unless the person is in violation of a commission regulation, order or stipulation pertaining to drilling, plugging or abandonment of a well." So long as the proposed drilling complies with applicable legal requirements, the Commission has no authority to deny a permit on the ground that the drilling activities may impair access to navigable waters, adversely affect • someone's recreational use of the area, or even pose a residual risk to "remarkable and unique" public interest resources.' Those concerns, while certainly legitimate, are addressed in other forums, such as the decisions of the Department of Natural Resources regarding oil and gas lease sales and plans of operation andthe decisions of local government regarding land use. Nonetheless, it cannot be denied that in a practical sense, the asserted interests of Greenpeace and its members could potentially be affected by an erroneous permit decision on the part of the Commission. The question is whether Greenpeace is "affected" in a legal sense: i.e., whether AS 31.05.080(a) is intended to allow persons besides the permit applicant (and perhaps. others owning interests in the affected property) to reopen Commission decisions on permits to drill? Perhaps because of a paucity of pertinent authority, the briefing provided to the Commission is less informative on this question than had been hoped. The Commission remains dubious that AS 31.05.080(a) is intended to apply to members of the public or entities such as Greenpeace that do not claim an ownership interest in directly affected property. Nevertheless, the Commission is hesitant on this record to rule as a matter of law that such persons may never qualify to obtain rehearing of a permit decision. For purposes of this order, the Commission assumes without deciding that Greenpeace has the right under AS 31.05.080 to request rehearing. IL. Was the Commission Required to Undertake a Second Consistency Review under the Alaska Coastal Management Program? One ground on which Greenpeace seeks rehearing of the Commission's permit decision is the assertion that the Commission has failed to comply with the requirements of the Alaska Coastal Management Program ("ACMP")..The. Commission disagrees. Because multiple authorizations from state "resource agencies" as well as federal agencies were required before BP could begin drilling (or conducting other activities under the Northstar Project), an ACMP consistency review process was coordinated by the Office of Management and Budget, Division of Governmental Coordination. See AS 44.19.145(a)(11); 6 AAC 50.030.. Pursuant to this consistency review, in which the Commission .participated (see Appendix 1 to this order), the Division of Governmental Coordination made a final determination, on February 4, 1999, that the Northstar Development Project is consistent with the ACMP. See Exhibit 4 to Briefing on Greenpeace's Right to Petition for Rehearing. It is clear from the Project Description and other portions of the consistency determination documents that this consistency determination covers the drilling of wells such as that whose permit Greenpeace seeks to challenge on rehearing here. The project description stated, in relevant part: Twenty-three wells will be drilled initially. One well will be a Class I disposal well for non-hazardous and Resource Conservation and Recovery Act ' To the extent that the Alaska Coastal Management Program has supplemented the Commission's authority, such considerations might be addressed under that additional authority. This question is considered below. z No doubt every government decision has the potential to affect the public or members of the public (which probably explains why the government is involved in the first place).. For example, an improvidently issued driver's license might lead to vehicle collisions on the part of an unqualified driver. As far as the Commission is aware, however, the Division of Motor Vehicles is not required to accept petitions from members of the public to rehear decisions to issue a driver's license. ORDER DENYING REHEARING Page 2 of 6 • (RCRA) exempt waste generated by drilling and camp activities. Fifteen wells will be .for oil production, and 7 wells will be for gas injection into the reservoir to boost production. Id. at 2-3. Moreover, Attachment C to the consistency determination, to which the Commission contributed, includes an extensive analysis of the risk of blowouts during the drilling. of wells and a decision to impose seasonal restrictions on drilling. See Appendix 2 to this order. The basis for Greenpeace's contention that a second consistency review must be performed for these same wells appears to be the fact that the Commission's permits to drill are not listed in the February 4, 1999, consistency determination as among the state and federal. authorization to which "[t]his fmal consistency determination applies." Exhibit 4, supra, at 3. This omission is immaterial, however. A consistency determination covers activities or projects, not permits. The listing of federal and state authorizations is presumably provided as a convenience to the permitting agencies. In relevant part, 6 AAC 50.990(a)(6) defines "consistency determination" as (A) a document that (i) contains a brief description of the project under review and the scope of the project; (ii) states whether the project is .consistent, consistent with stipulations, or is not consistent, and provides a brief statement. of the reasons for that determination; ... . (Emphasis. supplied.) "Project" in turn is defined as "an activity or use that will be located in or may affect the. coastal zone of the state and that is subject to consistency review under 16 U.S.C. 1456(c) ...." 6 AAC 59.990(a)(22) (emphasis supplied). Thus, there is no doubt that the drilling of wells as part of the Northstar Development Project has been determined to be consistent with the ACMP. Assuming without deciding that the Commission is required under the ACMP to ensure that the activity proposed to be permitted under AS 31.05.090 is consistent with the ACMP before a permit to drill is issued, the Commission has satisfied that requirement here by not issuing Northstar Project permits to drill before the Division of Governmental Coordination made its final consistency determination for that project. Greenpeace, of course, had abundant opportunity to participate in the public process by which that final consistency determination was reached. III. Was Greenpeace Entitled to Notice of the Permit Application? In accordance with the Commission's long-standing practice under and interpretation of AS 31.05.090, the permit to drill in this case was issued without public notice or other notice to persons besides the permit applicant.3 Greenpeace asserts that this violated its due process rights as well as the provisions of AS 31.05.050(b). The Commission believes the due process claim is without merit. Due process protections are not triggered by every government action, but only by those government actions that potentially impair a 3 Pursuant to 20 AAC 25.537(a), following issuance of the permit the Commission published the fact that the permit had been issued and certain information about the well in question. ORDER DENYING REHEARING Page 3 of 6 i • person's property or liberty. Greenpeace has not claimed any property or liberty interest within the purview of the due process clause that might be at stake in the decision to approve the permit to drill in this case. See State, Dept. of Natural Resources v. Universal Education Society, Inc., 583 P.2d 806 (Alaska 1978). The statutory provisions cited by Greenpeace are inapposite. AS 31.05.050(b) does not address when notice must be given but rather specifies how notice is to be given when notice: is "required by this chapter." AS 31.05 requires notice for well spacing exceptions, AS 31.05.100(b), and for compulsory unitization, AS 31.05.110(b), but not for permits to drill, AS 31.05.090. Seemingly more pertinent to Greenpeace's concern is AS 31.05.060(b), which in relevant part provides: Any action by the commission under this chapter that has application to a single well or single field need not comply with the provisions of AS 44.62.330 - 44.62.630 [the adjudication provisions. of the APA], but shall be performed in accordance with regulations of the commission designed to afford persons affected by the action notice and an opportunity to be heard. Contrary to Greenpeace's claim, the Commission has promulgated notice and petition. regulations. See 20 AAC 25.540 (general provisions for hearings on petitions ("request[s] to issue an order affecting a single well or a single field")); 20 AAC 25.055(d) (specific notice provisions for spacing. exceptions); 20 AAC 25.252(1) (notice for underground disposal or storage). These regulations do not, however, cover applications for permits to drill. Permits to drill are addressed in 20 AAC 25.005, which does not mandate notice. The question is whether the Commission is required to provide notice of those applications to others like Greenpeace. The Commission believes the answer is no. Permits to drill are governed by a specific statutory provision that contemplates a limited and abbreviated administrative process. AS 31.05.090 requires the Commission to issue a permit to drill in the absence of a violation on the applicant's part. And it requires the Commission to act "promptly" "upon receipt of notification and fee" from the applicant. These provisions do not appear to be consistent with public notice or any other extended administrative process for deciding on applications for permits to drill. The Commission's practice has in fact been to act promptly on such applications, typically issuing a permit less than two weeks. after receiving the application Sometimes, as where an operator decides to substantially change the drilling objective (bottom-hole location) after beginning drilling operations, an even more rapid decision on an application is needed to avoid keeping a drilling rig in costly stand-by status. This would not be possible if public notice were required. Furthermore, as pointed out in the Commission's earlier order, under 20 AAC 25.537 almost all of the material submitted in support of an application for a permit to drill must be kept confidential. This would make participation in the permit decision by others besides the applicant awkward at best and next to meaningless at worst. The Commission believes, then, that the legislature did not intend the issuance of permits to drill under AS 31.05.090 to be subject to advance notice to members of the public. If AS 31.05.060(b) applies at all to those permits, the permit applicant is the only person deemed to be "affected." It is worth noting in this connection that when the legislature enacted AS 31.05.060(b) (Sec. 7, ch. 160, SLA 1978),. it .was with the purpose of expediting the decision-making process in matters concerning a single well or single field by exempting those matters from the adjudication provisions of the Administrative Procedure Act ("APA"). Speaker Malone, a co-sponsor of the legislation, explained in. ORDER DENYING REHEARING Page 4 of 6 committee meeting that it was "designed to bean 'anti-red-tape' provision for special consideration of a single field." H. Fin. Comm. Minutes, Apr. 27, 1978. See Appendix 3 to this order. A lot of times, he advised, it isn't in the best interest of the State to go through the Administrative Procedure Act for a minor situation. He stated there ought to be simplified procedures in instances involving a single well or field. Id. By comparison, the APA itself requires notice only to "the parties," AS 44.62.420, who consist of "the agency, the respondent, and a person, other than an officer or an employee in an official capacity, who has been allowed to appear in the proceeding," AS 44.62.640(b)(4). Certainly by enacting an "anti- red tape" provision the legislature did not intend the concept of "persons affected by the action" under AS 31.05.060(b) to be broader than the very limited class of persons entitled to notice in APA adjudications. In the case of an application for a permit to drill, the equivalent of the "respondent" is the applicant. See 1978 Inf. Op. Att'y Gen. (Jan. 31; 663-78-0446), 1978 WL 18334, Appendix 4 to this order. 1V. Has Greenpeace Demonstrated Any Substantive Basis to Revisit the Commission's Decision to Issue the Permit to Drill? Greenpeace asserts that the Commission failed in various respects to comply or to require BP to comply with substantive requirements of the Commission's regulations. However, Greenpeace .has provided no basis for its conclusory assertions, and the Commission is aware of none. In addition, some of the regulations Greenpeace cites do not apply at all to an application for a permit to drill but instead apply to post-drilling operations, some of which have their own review and approval procedures.. For example, Greenpeace complains that the Commission "failed to require abandonment plans in accordance with 20 AAC 25.105," but that regulation requires an operator to submit and. obtain Commission approval of such a plan "before work is begun to abandon a well," not at the time an application for a permit to drill is made. Greenpeace also asserts that the Commission failed to "conduct an analysis of coastal impacts from the well drilling, well operations, the underground injection well, or of the geophysical hazards associated with well-drilling and operation." As the Commission noted in its earlier order, coastal impacts were addressed as part of the ACMP consistency review and mitigation of coastal impacts are also implicitly addressed in the Commission's regulations. There is no further requirement for the Commission to analyze coastal impacts. Contrary to Greenpeace's assertion, geophysical hazards were considered by the Commission in reviewing the permit to drill. See 20 AAC 25.005(c)(4). Accordingly, the Commission fmds no basis for rehearing with respect to its permit decision in this matter. V. The Commission Is Alwavs Open to Receiving and Considering Information Bearing on Compliance or Non-compliance with Applicable Laws, Regulations, Orders, or Permit Conditions. Finally, it is worth repeating what was said in the Commission's earlier order. Whether or not the AS 31.05.090(a) rehearing procedures apply or are invoked in a given situation, -the Commission itself has continuing authority to consider, investigate, and act on information received from whatever source, concerning compliance with the ORDER DENYING REHEARING Page 5 of 6 statutory and regulatory provisions that the Commission administers. See, e.~., AS 31.05.030(b); 20 AAC 25.535.... Consequently, any material information. that Greenpeace [or others] may choose to supply the Commission, whether through a rehearing proceeding if held or by informal means, will be given due consideration. NOW THEREFORE IT IS ORDERED: The petition for rehearing is DENIED. DONE at Anchorage, Alaska, this 9th day of May 2001. ~ :~ ~` r «~~ ~~ ~ ~; ~ ~ _ s...=~ s ° C 1 ~~ ,~: ~ ,r 'p, A, ~~~~ A S h '~ ~3G y .b (~1~~ W~ ,.' r ; ~qr ' r d i ~ '{~~Q ~ _~ Alaska Oil and Gas Conservation Commission Julie M. Heusser, Commissioner Alaska Oil and Gas Conservation Commission I certify that on May 9, 2001, a copy of the above was mailed to each of the following at their addresses of record: Nancy S. Wainwright BPXA Attorne s, Jeff Fel an/ usan Orlansky Jody o e, ecutive Secretary This decision is .the final order of the Alaska Oil and Gas Conservation Commission. Any Appeal to Superior Court must be brought within 30 days from the date that this decision is mailed or otherwise distributed. Cammy Oec li Taylor, Chair Alaska Oil d G Conservation Commission aniel T Seamount Jr Commissioner ORDER DENYING REHEARING Page 6 of 6 STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 W. 7th Ave., Suite 100 Anchorage, Alaska 99501-3539 Re: THE PETITION OF GREENPEACE, ) INC., for Rehearing of Approval of ) Permit to Drill No. 201-027 (API No. ) 50-029-22003-00). ) May 9, 2001 ORDER DENYING REHEARING In its Order Granting Rehearing for Limited Purpose and Denying Request for Stay, the Commission stated that it would first consider whether Greenpeace, Inc. ("Greenpeace") has the right to apply for rehearing of the Commission's approval of an application for a permit to drill and would then proceed accordingly. The Commission stated that it would base its determination on any briefmg filed by Greenpeace and BP Exploration (Alaska) Inc. ("BP") in the similar matter of Permit to Drill No. 200-211 (which briefmg could also address any additional considerations specific to this Permit to Drill No. 201- 027). Having now considered the briefs filed by Greenpeace and BP, the Commission declines to rule on what might be called the "standing" issue but instead denies rehearing on the merits. Because the petitions and the issues in the two matters are identical in almost all material respects, the Commission's decision here is based on the reasons set out in the attached Order Denying Rehearing in the matter of Permit to Drill No. 200-211, as supplemented by the following. I. North Slope Borough Coastal Management Program One of the claims Greenpeace made regarding Permit to Drill No. 200-211 concerns compliance with the Alaska Coastal Management Program ("ACMP"). Greenpeace has repeated that claim here but has added the assertion that the Commission "failed to comply with the North Slope Borough CMP Policy Greenpeace's reference to the North Slope Borough Coastal Management Program ("NSBCMP") is redundant, because the Northstar Development Project Final Consistency Determination encompasses consistency with the NSBCMP. "Standards of the ACMP include state standards found in regulations .. . and the enforceable policies of the local coastal districts. In this case, the North Slope Borough is the affected coastal district for the Northstar Project." Northstar Development Project Alaska Coastal Management Program Consistency Analysis at 1, copied as Appendix 1 to Order Denying Rehearing, Permit to Drill No. 200-211 (emphasis supplied). The NSBCMP policies identified by Greenpeace were specifically addressed in this Consistency Analysis, at 30-32. See Appendix A to this order. II. Other Alleged Errors In addition to the same substantive errors alleged in Greenpeace's petition regarding Permit to Drill No. 200-211, Greenpeace alleges here that the Commission has failed to protect freshwater from contamination and has failed to witness certain tests or operations. The petition does not specify, however, the nature of the alleged failure(s) concerning protection of freshwater or how such failures ORDER DENYING REHEARING Page 1 of 2 ~ ~ might relate to the Commission's decision to issue Permit to Drill No. 201-027. As pointed out previously, the Commission is required under AS 31.05.090 to issue a requested permit to drill "unless the drilling of the well is contrary to law or a regulation or order of the commission, or unless the person is in violation of a commission regulation, order or stipulation pertaining to drilling, plugging or abandonment. of a well." Protection of freshwater is an objective of several provisions of the Commission's regulations, but Greenpeace has not explained, nor is the Commission aware, how the drilling of the well in question would be contrary to any of those provisions. Similarly, even if it were true that the Commission failed to carry out certain inspections (and as far as the Commission is aware, the appropriate inspections have in fact been carried out), such failure would not retroactively invalidate a permit to drill that was necessarily issued before the occasion to perform the inspections could even arise. NOW THEREFORE IT IS ORDERED: The petition for rehearing is DENIED. DONE at Anchorage, Alaska, this 9th day of May, 2001. f..,. ,. Cammy Oechs 'Taylor, Chair Alaska Oil and as Conservation ommission aniel T. Seam t, Jr., Commissioner Alaska Oil and Gas Conservation Commission yl ~ ~~ Julie M. Heusser, Commissioner Alaska Oil and Gas Conservation Commission I certify. that on mailed to each o the following at their addresses of record: Jr ~~ IG, Wai nwright/Feldman/Orlansky Jod olo e, cutive Secretary This decision is the final order of the Alaska Oil and Gas Conservation Commission. Any Appeal to Superior Court must be brought within 30 days from the date that this decision is mailed or otherwise distributed. ORDER DENYING REHEARING Page 2 of 2 ~3 STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 W 7th Ave., Suite 100 Anchorage, Alaska 99501 Petition of Greenpeace, Inc., ) for Rehearing of Approval of Permit to Drill No. 201-041 ) (API No. 50-029-23005-00) (Northstar Unit 29) ) Apri19, 2001 ORDER GRANTING REHEARING FOR LIMITED PURPOSE AND DENYING REQUEST FOR STAY On March 5, 2001, the Commission approved an application filed by BP Exploration (Alaska) Inc. ("BP") for a permit to drill a well, pursuant to AS 31.05.090 and 20 AAC 25.005. On March 28, 2001, Greenpeace, Inc. ("Greenpeace") filed a petition challenging the permit approval under AS 31.05.080. The petition also requests "a stay of the permit pending a hearing on the merits of this petition." This petition is similar to the petition Greenpeace filed on February 1, 2001, challenging the Commission's approval of Permit to Drill No. 200-211. In that matter, the Commission granted rehearing for the limited purpose of allowing briefing and consideration of the question of whether Greenpeace has the right to apply for rehearing of the Commission's approval of an application for a permit to drill. For the reasons set out in that order, the Commission will also grant rehearing in this matter for the limited purpose of considering the same question. As in the first matter, the Commission will then determine whether it may hear Greenpeace's petition on the merits and will proceed accordingly. The Commission will base its determination on the briefing that was filed in the matter of Permit to Drill No. 200-211, except that if Greenpeace or BP believes that there are additional considerations specific to Permit to Drill No. 201-041 that should be taken into account, it may file supplemental briefing in this matter. A party that wishes to file supplemental briefing should notify the Commission of its intention in writing within five days after the date shown on the certificate of distribution below (however, if one party files supplemental briefing the other party shall have the right to file responsive briefing within 10 days). ORDER GRANTING REHEARING FOR LIMITED PURPOSE AND DENYING REQUEST FOR STAY Page 1 of 2 • ~ Regarding Greenpeace's request to stay the permit pending a hearing on the merits, the Commission is not aware of any facts showing that a temporary emergency order is needed "to protect against immediate harm to public health or safety," see 20 AAC 25.539, or that a stay is otherwise warranted. Accordingly, the request for a stay will be denied. NOW THEREFORE IT IS ORDERED: 1. Greenpeace's petition for rehearing is preliminarily granted for the limited purpose of allowing consideration of the question of whether Greenpeace has the right to apply for rehearing of the Commission's approval of an application for a permit to drill, as more fully set out in the February 9, 2001, Order Granting Rehearing for Limited Purpose and Denying Request for Stay in Re: The Petition of Greenpeace, Inc., for Rehearing of Approval of Permit to Drill No. 200-211 (API No. 50-029- 22996-00). 2. The request for a stay is denied. DONE at Anchorage, Alaska, this 9th day of A 001. ~,.•~ Dani . Seamount, r., Commissioner /~ ®Ot~ Alaska Oil and Gas Conservation Commission vc ~~i~~, ~ ~;, ' 'yam ~~ ,;~~ .- •~ ~ _ ~~~'~j < .~` ~ " ~ ~`' 1 t ~ ~~ ~ ~~~.. ~ gal. ~~~ `~~'~UNiCp I certify that on n 9, 2001 a copy of the Above was mailed and Faxed to each of the following: Nancy Wainwright Feldman/Orlansky n ~ n n r Camille Oechsli Taylor, Commissi r Alaska Oil and Gas Conservation Commission Julie M. Heusser, Commissioner Alaska Oil and Gas Conservation Commission Jody J. ~dloml~i Executiv Secretary ORDER GRANTING REHEARING FOR LIMITED PURPOSE AND DENYING REQUEST FOR STAY Page 2 of 2 n". ALASKA OIL AND GAS CONSERVATION CONIl~II S S I ON 333 WEST 7TH AVENUE, SUITE 100 ANCHORAGE ALASKA 99501-3539 FACSIMILE TRANSMITTAL SHEET TO: Nancy Wainwright (907)345-7666 Jody Colombie Feldman/Orlansky (907)274-0819 Executive Secretary DATE: Apri16, 2001 Total No. Of Pages Including Cover: 3 Re: Order Granting Rehearing for Limited Purpose and Denying Request for Stay. NOTES/COMMENTS Phone No. (907) 793-1221 Fax No. (907) 276-7542 ~~~~~~~~~~~~~~~~C~~~~~C~~C~~~~~~~~~~~~~~~C~C~~~~~~C~~~~~~~~C~~C~~C~~~~~~~C~~~C~~~~C~C~~~C~~~~~~~C~~~~~~C~~~~C~~~~C~~~~~~~C~ ~ P. 01 ~ ~ ~ TRANSACTION REPORT ~ ~ ~~ APR-09-01 MON 03;13 PM ~ ~ ~ ~ SEND(M) ~ ~ ~ ~ DATE START RECEIVER TX TIME PAGES TYPE NOTE M# DP ~ ~c ~ ~ APR-09 03 12 PM 2740819 1'11" 3 SEND ( M) OK 117 ~ ~c ~ ~~~~~~~~~~~~~~~~~~~~~~c~~~~~~~c~~~~c~~c~~~~~~~~~~~~~~~~~~~~~~~~~c~~~~~~~~~~~~~~~~~~~~c~~~~~c~~~~~~~~~~~~~~c~~~~c~ ~~~~~~~~~~C~~~~~C~~~~~~~~~~~C~~~C~~C~~C~~C~~~~~~C~~~~~~~~~C~C~~~~~~~~~C~C~~~~~~~~~~~~C~~~C~~C~~C~C~~~~~C~~~C~~~~~~~~C~~~~C~~K~ ~ P, 01 ~ ~ • TRANSACTION REPORT ~ ~ ~, APR-09-01 MON 03:15 PM ~ ~ ~ ~ SEND(M) ~ ~ ~ ~ DATE START RECEIVER TX TIME PAGES TYPE NOTE M~ DP ~ ~ ~ ~ APR-09 03:15 PM 3457666 ~~'~~" 0 SEND ( M) BUSY 114 :K ~ ~ ~~~~~~c~~c~~~~~~~~~~c~~~~~~~~~~~~c~~~~~~c~~~~~c~c~~~~~~~~c~~~~~~~~~c~~c~~~~~~~~~~~c~~~~~~~~~~~~~c~~~c~~~~~~~~~~~~~~~~ ~~ - ~ Nancy S. Wainwright Attorney at Law 13030 Back Road, Suite 555 ~` Anchorage, Alaska 99515-3538 ~Q~ PETITION TO THE '=~~,- f ALASKA OIL AND GAS CONSERVATION COMNIISSION ~,, STATE OF ALASKA Petition of the Decision to Approve Development Well ) 50-029-23005-00 BP EXPLORATION (ALASKA) INC ) Petitioner Greenpeace, Inc. hereby petitions the Alaska Oil and Gas Conservation Commission, State of Alaska, in accordance with AS 31.05.080 and provides the following information: (1) This petition is timely filed within 20 days of the notice of AOGCC decision. (2) Case reference number: 50-029-23005-00 (3) Decision on which petition is filed: Decision of the AOGCC to allow permit the development well 50-029-23005-00 BP EXPLORATION (ALASKA) INC NORTHSTAR UNIT NS-29 201-041 APPROVED: 03/05/2001 SERVICE SURF: 1329FT FSL AND 649FT FEL, SEC 11, T13N, R013E, UM ARCTIC SLOPE BOTM: 1698FT FSL AND 580FT FEL, SEC 03, T13N, R013E, UM LSE:. ADL0312799 NORTHSTAR, IVISHAK UNDEFINED OIL POOL (4} Statement of Points Raised in Petition: Note: in the previously filed petitions (for well NS-26 and NS-27) Petitioner raised these same points, and the Commission responded to a number of these points [fn. 1 to Order of 2/9/01]. Petitioner respectfully disagrees that the Northstar ACMP review included the Petition to the AOGCC 3/28/01 (NS-29) page 1 . ~ permits to drill. In fact, DGC specifically removed these permits from the review; and they are not listed in the Conclusive Consistency Determination of February 4, 1999; nor are the coastal zone impacts of the drilling identified or analyzed. There are other points with which Petitioner disagrees, and those will be presented by way of subsequent briefing. Petitioner specifically alleges: a. The AOGCC has failed to comply with the Alaska Coastal Management Program (ACMP) and has failed to coordinate a consistency review of this well drilling permit. AS 46.40; 6 AAC 50. The AOGCC failed to comply with the North Slope Borough CMP Policy 2.4.4(b);(f). b. The AOGCC has failed to promulgate notice and petition regulations, or give notice of the single well permit, in accordance with AS § 31.05.050 (b). The action of the AOGCC to approve the permit, without notice, violates Petitioner's administrative due process rights. c. The AOGCC has failed to require sufficient primary well control for drilling. 20 AAC 25.033. d. The AOGCC has failed to require sufficient secondary well control for primary drilling and completion 20 AAC 25.035. e. The AOGCC has failed to require the applicant to comply with 20 AAC 25.036. f. The AOGCC has failed to require the applicant to comply with 20 AAC 25.047, or to ensure that the Seal Island reserve pitldike has been installed to facilitate the Petition to the AOGCC 3/28/01 (NS-29) page 2 • • safety of the drilling operation, and to prevent contamination of freshwater, seawater, and damage to the surface environment. g. The AOGCC has failed to require abandonment plans in accordance with 20 AAC 25.105. h. The AOGCC has failed to require automatic shut in equipment to meet the requirements of ZO AAC 25.265. i. The AOGCC has failed to require, and BPXA has failed to comply with 20 AAC 25.526. in that BPXA has failed to carry on all operations and maintain the property at all times in a safe and skillful manner in accordance with good oil field engineering practices and having due regard for the preservation and conservation of the property and protection of freshwater. j. AOGCC has failed to conduct an analysis of coastal impacts from the well drilling, well operations, the underground injection well, or of the geophysical hazards associated with well-drilling and operation. k. AOGCC has failed to protect freshwater from contamination by oiUgas/mud during drilling, production, and abandonment operations; 1. The AOGCC has failed to carry out its duties to (1)witnesses Blow Out Prevention Equipment (BOPE) testing following installation of the surface casing on each rig at start up, after major moves and every two months on a routine basis; (2) conduct diverter tests; (3) witness, new rig or reactivated rigs start-ups where a diverter is Petition to the AOGCC 3/28/01 (1VS-29) page 3 • required, and all wells requiring a diverter because of known or probable shallow gas sands. m. The AOGCC has permitted the operator BPXA to drill wells that have not been analyzed as part of the ACMP or EIS process, and for which appropriate federal and state permitting analysis has not been conducted. Two of the Northstar wells (NS 27 and NS 29) "spare" wells, and one well (NS-26) was listed as a federal well. AOGCC has permitted these wells to be drilled with no ACMP or UIC analysis. n. There has been no ability of the public to comment on NS 29 because it was noted as a spare well. It is impossible for the public to comment on a well for which no information is given. Notice of Intent to file Supplemental Petition Petitioner hereby notifies the AOGCC that it will supplement the points raised in this petition, after receipt of the agency record. Request for Stay Petitioner hereby requests a stay of the permit pending a hearing on the merits of this petition. Request for Information Petitioner requests that the following information be provided: total depth, bottom-hole location and well status after the Well Completion or Recompletion Report and Log (Form 10-407) is filed; regular production data and regular Petition to the AOGCC 3!28/01 (NS-29) page 4 • i production reports, as required to be filed by the operator each month; injection data and injection reports, as required to be filed by the operator each month. Respectfully submitted this 28t" day of March, 2001. LAW OFFICES OF NANCY S. WAINWRIGHT ~ ~- Nancy S Wainwr t on behalf of Greenpeace, Inc. Petition to the AOGCC 3!28!01 (NS-29) page 5 ~ ~ CERTIFICATE OF SERVICE I certify that on March 28, 2001 a copy of the following were served by fax and mail on: BPXA Attorneys Jeff Feldman Susan Orlansky Feldman & Orlansky 500 L Street, Suite 400 Anchorage, AK 99501 Documents served: Appeal of NS 29 [50-029=23005-00] Dated: 3/28/01 1 y . ~~ ~ GC ~~~~ Nancy - . Wainwri ht Attorney for Appellant Greenpeace AOGCC appeal (NS 29) Certificate of Service 03/28/01 ~ • Nancy S. Wainwright Aitorney at Law 13030 .Back Road, Suite 555 A,tack~oKage, Alaska 99515-353$ PETITION TO THE ALA.S.ICA OIL AND GAS CONSERVATION COIVIIV)7SSION STATE OF ALASKA Petition of the Decision to Approve Development Well ) 50-029W23005-00 BP EXPLORATION (ALASKA)1NC ) :. ) Petitioner Greenpeace, bnc. hereby petitions the Alaska Oil and Gas Conservation Commission, State of Alaska, in accordance with AS 31.OS.080 and provides the following iut:tformation: (~) This petitiozz is timely filed within 20 days of the notice of AOGCC decision. (2) Case zeference number: 50-029-23005-00 (3) Decision on which petition is fled: Decision of the AOGCC to allow permit the development well 50-029-23005-00 BP EXPLORATION (ALASIS.A) INC NORTHSTAR UNIT NS-29 201-041 APFROVED:03/05/2001 SERVICE SURk': 1329FT k'SL AND 649k'T FEL, SEC 11, T13N, R013E, UN1 ARCTIC SLOPE BOTM~ 1598~'T FSL ANp 580FT ,FEI,, SEC 03, T13N, RO13E, LJNI LSE: ADL0312799 NORTHSTAR, IV'ISHAK UNDEFINED OZL POOL (4) Statement of Points Raised in Petition: Nate: in the previously fledppetitivns (for Weil NS-26 and NS-27) Petitioner raised these same points, and the Commission responded to a number of these points [fn. I to Order of 2/9/01 ]. Petitioner respectfully disagrees that the Northstar ACNI.P review itzcluded the Petition to theAOGCC 3/28/01 (NS 29) page 1 i • permits tv drill. In fact, DGC specifically removed these pexzx~its from the review; and they are not listed in the Conclusive Consistency Determination of February 4, 1999; nor are the coastal zone impacts of the drilling identified ox analyzed. There are other points with which Petitioner disagrees, and those will be presented by way of subsequent briefmg..:~ _ ..z; . Petitioner specifically alleges: a. The AOGCC has vfailed to comply with the Alaska Coastal Management Program (ACMP) and has failed to coordinate a consistency review of this well drilling permit. AS 46.40; 6 AAC 50. The AOGCC failed to comply with, the North Slope borough CMP Policy 2.4.4(b);(f). b. The AOGCC has failed to promulgate notice and petition regulations, or give notice of the single well permit, in accordance with AS § 31.05.050 (b). The action. of the AOGCC to approve the permit, without notice, violates Petitioner's administrative due process rights. c. The AOGCC has failed to require sufficient primary well control for drilling. 20 AAC 25.033. d. The AOGCC has filed tv require sufficient secondary well control for prirrtary drilling and completion 20 AAC 25.035. e. The AOGCC has failed to require the applicant to comply with 20 AAC 25.036. I: The A,OGCC has failed to require the applicant to comply with 20 AAC 25.047, or to ensure that the Seal Island reserve pit/dike has been installed to facilitate the ,Perirton to the AOGCC 3,'28/01 (NS-29} page 2 • safety of the drilling operation, and to prevent contamination of freshwater, seawater, and damage to the surface environment. g. The AOGCC has wiled to require abandonment plans in accordance with 20 AAG 25.105. h. The AOGCC .has failed to require automatic shut in equipment to nrxeet the requirements of 20 AAC 25.265. i. The AOGCC has failed to require, and ~PXA has failed to comply with 20 AAC 25.526. izt that BP~.A has failed to carry on all operations and maintain the property at all times in a safe and sl~illful manner in accordance with good oil field engineering practices axtd having due regard for the preservation and consexvatioz~ of the property and protection of freshwater. j. AOGCC has failed to conduct an analysis of coastal impacts from the well drilling, well operations, tltebundexgxound injectio'n~ well, or of the geophysical hazards associated with well-drilling and operation. 1~. AOGCC has failed to protect freshwater from contamination by oil/gaslmud during drilling, production, and abandonment operations; 1. The AOGCC has failed to carry out its duties to (l)wxtnesses flow Out .Prevention Equipment ($OPE) testing following installation of the surface casing on each rig at start up, after major moves and every two months on a routine basis; (2) cotzduct diverter tests; (3) witness, new rigor reactivated rigs start-ups where a diverter is Petition to the AOGCC 3/28/01 (NS-29) page 3 • • required, and all wells requiring a diverter because of known or probable shallow gas sands. m. The AOGCC has permitted the operator BP~'A to drill wells that have not been analyzed as part of the ACMP or EIS process, and for which appropriate federal atad state permitting analysis has not beeza conducted. Two ofthe Northstar wells (NS 27 and NS 29) "spare" wells, and one well (NS-26} was listed as a federal well. AOGCC has permitted these wells to be drilled with no ACMP or UIC analysis. n. There has been no ability of the public to comment on NS 29 because it was noted as a spare well. It is impossible for the public to continent on a well for which no information is given. Notice of>lntent to file Supplemental Petition Petitioner hereby notifies the AOGCC that it will supplencaetat the points raised in dais petition, after receipt of the agency record. Request for Stay Petitioner hereby requests a stay of the permit pending a hea~ng on the zaaexits of this petition. Request for Information Petitioner requests that the following information be provided: total depth, bottom-hole location and well status after the Well Cozaapletion oz' Recompletion Report and Log (Form 10-407) is filed; regular production data and regular Petition td the,F(000'C 3/28/Oa (NS-29f page 4 ! • production reports, as required to be flied by the operator each month; injection data and injection reports, as required to be bled by the operator each month. Respectfully submitted this 28"' day of IVlarch, 200I . LAW Ok'FICES Ok' NANCY S. WAINWRIGHT ~. Nancy S Wainwr t on beb;alf of Greenpeace, Inc. Petttton to the.AtOGCC 3/28/Oa (NS-29) page 5 iy ,, ~ Nancy S. Wainwright Attorney at Law 13030 Back Road, Suite 555 Anchorage, AK. 99515-353$ "~elephon.e: (907) 345-5595; Fax: (907) 345-5595 E-mail Add~ess:nsw(asiaska.net FACS~M~LE COVER SHEET Date: March 28, 2001 Attention: AOGCC fax (907) 27b-7542 From: Nancy aS. Wainwright ~ , . Re: Noxthstar Pezxnit to Dx~11 App a a150-029-23005-.00 Certi~eate of Service Fax no. (907) 345-3629 Phone no. (907) 345.5595 NUMBER OF PAGES, INCLUDING COVER SHEET: 2 ~~~~~~~ MaR 2 s zoos ~4lasfca Oit & Gas Cons.. Cammfsaior AncAaage If a-ry pages are unclear or do not arrdve, please call (907) 345-5593, C~R'~TFICATE OF SERVICE L I certify that on March 28, 2001 a copy of the following wexe served b3' fax and rxaail on: SQ~,A, Attorneys Jef£1~eldnnan Susar,-, Orlansky k'eldman & Oxlansky 500 L Street; Suite 400 Anchvxage, AK 99501 Docutxaents sexved: Appeal DENS 29 [50-029=23005-00] Dated: 3/28/01 ~~~ Nancy . Wainwxi ht Attorney fox Appellant Gxeenpeace AOGCC appeal (NS 29) Certificate of Service 03/28/0] ~ ~ a Nancy S. Wait~vvxx~ht A,ttozney at Law 13030 Back Road, Suite SSS Azxck~o~age, AK 995 ~ 5-3538 Telephone: (907) 345-5595; Fax: (907) 345-5595 E-mail Address:nsw@alaslca_net FACSIMILE COVER SHEET Date: Maxch 28, 2001 Attentioa<a: A,OGCC fax (907) 276-7542 P>rozn: Nancy S. Wainwright Re: Norkhstar Perxxut to Drill Appea~ 50-029-23005-00 Fax, no. (907) 345-3629 Pk~one no. (907) 345-5595 NUMBER OF PAGES, INCLUDING COVER SHEET: 6 If arty pages are unclear or do trot arrive, please call (907) 345-5595. MAR 2 8 2001 Alma Oil ~ Gas Cons. Commiaeior~ Mdtor~ge Post-tt® Fax Note 7671 Date Co./Dept. Phone # n \ A n~uc ~ ':/ ~C~~~~~~~~~~~~~~~~~~~~C~~~~~~tC~~t<~~~~~~~~tC~~~~~~~~~~~~~~~~~~~~~~~tC~~~tCtCtC~~~tC~~~~~~~~~~~~~~~~~~~~~~~~~~tC~~~ ~ P, 01 ~ ~c ~ ~ TRANSACTION REPORT • ~ ~ MAR-28- 01 WED 05.29 PM ~ ~ ~ ~ SEND (M) ~ ~ ~ %K DATE START RECEIVER TX TIME PAGES TYPE NOTE M# DP ~ ~ ~ ~ MAR-28 05 26 PM AG OIL & GAS 2'32" 8 SEND (M) OK 084 ~ ~ ~ ~ ~ ~c ~ TOTAL ~ ~ 2M 32S PAGES ~ 8 %K ~; ~ ~~~c~~~~~~~~~~~~c~~~~~~~c~~~~c~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~c~~~~c~~~~~~~c~~~~~~~~~~~~~~~~c~~~~c~ ~ Nancy S. Wai~w~xz~ht ,A,ttorneq at Law 1303Q Back Road, Suite 555 A~c~o~age, AK X95 i 5-3538 Telephone:(907j 345-5595; Fax: (907)345.5595 E-nail Address:nsw@alaslca.zaet FACSIMILE COVER SHEET Date: Mati"c~4 2t3, 2001 ~ , , Atte~taoaa: AOCiCC fax (907) 276-7542 Fxox><~; 1Vancy S. Wainw~ght Re: Nc-rthstar Pexz>nuit to D~711 Appea~ 50-029-23005-00 Fay xto• (907) 345-3629 Phone nv. (907) 345-5595 MAR ~ ~ 24Q1 Alaska Oit ~ Gas Cans. Commir~ron Mc~iiorage
