More Alaskan Comic Relief

I guess we change with age. So instead of getting excited about the upcoming addition of Mad Magazine, like already blogged upon the significance this read, I have found a substitute – Alaskan style comic relief at its best. Once again, it is called the Petroleum News. I don’t know if this is a national publication, but for sure the Alaskan edition is primed with laughable materials galore and in the running to win the coveted Uncle Eddie Award, for doing dumb things with a smile. Just how many gas pipeline export projects are wasting away this state’s future? Look, read Lincoln’s lips: Chapter 15C – Alaska Natural Gas Transportation Act, §719J – EXPORT LIMITATIONS: Any exports of Alaska natural gas shall be subject to the requirements of the Natural Gas Act[15 U.S.C. 717 et seq.] and section 103 of the Energy Policy and Conservation Act[42 U.S.C. 6212], except that in addition to the requirements of such Acts, before any Alaska natural gas in excess of 1,000 Mcf per day may be exported to any nation other than Canada or Mexico, the President must make and publish an express finding that such exports will not diminish the total quantity or quality nor increase the total price of energy available to the United States.” Get it Paul Jenkins! Confused this one man attack? Well Paul at one time was Bill Allen’s side kick for Voice of the Times, another comic. But the Petroleum News comic relief goes into boring detail in almost every edition about this state’s pie in the sky pipe-dream wet-dreams, about a big pipeline idea that has about as much credibility for success as did Bill Sheffield’s train depot. And they placed him in charge of the Anchorage Port? I guess having a failed project named in your honor is vogue here in the “Lost Frontier”. Yes Don Young can boast this fame and lost fortune, for the failed Pt. McKenzie wood chip export run amuk project along with the M.V. Susitna. It appears that in Alaska incompetence with respect to useless projects breeds a lucrative future for some. “Well son, I had a job for life with no responsibilities”! And it is easy to realize that these “Big” pipe wet-dreams will always remain just that, as instead of hiring engineers, most stalled projects are hiring lawyers! I wonder what may be hiding in the shadows. See they gladly excepted the money and have nothing to show for it. So far, all the money wasted could have purchased pipe and shovels and gas would be on its way! So when the Petroleum News goes overboard and tries to instill some semblance of accomplishment such projects, when in reality the only “mission accomplished” is wasted resources, it is nothing short a joke. And it is laugh after laugh, publication after publication from the Petroleum News, with respect to Pioneer Natural Resources’ predicament. This “Independent” seems to be going under with production declines averaging a negative 40% for this year alone, and they just started this venture! Glad I am not a shareholder holding nothing. It's a new oil field. Not really, as the majors walked away from these reservoirs a long time ago realizing it was not worth the risk. There is something to be said about the “Majors” and their thinking! At that rate of lost production, Pioneer cannot even pay for the daily costs of the drilling rig. So instead of sending 20,000 barrels each day to market, the target goal, it is losing ground and daily production is declining - down to a pathetic 4,000 barrels each losing day. And the royalty relief COO wants to place blame on Conoco, for shying Pioneer on water injection? Maybe that is why HailBurton is teaming up with the biggest pipe dream of them all, Great Bear, an outfit that thinks it can punch 200 wells a year into the permafrost to reach shale bearing reservoirs. And all that hoopla in efforts to produce about 5,000 barrels a day? Let’s just ask Phineas J. Whoopee for help, assisted by his 3D Magical Board to access if this pie-in-the-sky pipe-dream risk is worth it, or maybe the possibility it is all a smoke screen to woo the politicians – those that continue to get a failing grade on “Resource Economics 101”. It would cost about $2-billion just to poke the holes. And with the price of crude less production costs, royalty and fines for having to ship it down the only pipeline available, it will take about 1000 days to break even, or about three years, but by that time the production will most likely die down, less income. So we have before us just another “pipe-dream” romance which is in reality a “ridiculous” endeavor. And Yukon Pacific finally released its ownership of the Trans-Alaska-Pipeline ROW, as the original corridor was designed for two pipelines. See YP held the Right-of-Way along the Trans-Alaska-Pipeline for many years, in hopes that one of the major’s would become interested in a natural gas pipeline, that was 30-years ago, still just a pipe-dream. Look, as it was once explained, natural gas is the enemy to “Oil” companies, as it is a marketable commodity out of the ground. Take a Coleman stove to a gas producing well and in no time flat you can boil water, which means this commodity has very little hidden cost opportunities. On the other hand, crude oil has many, many loophole adjustments, so convoluted that when this stuff finally makes its way to a refinery then cooked, manipulated and regurgitated to motor gasoline, it fetches in excess of $230 dollars for a single barrel of the raw product, which is fetching about $100 dollars per barrel on the open market. So the “Big Oil” guys do give a rat's ass about a gas pipeline, as any gas taken away from the field, it hurts the bottom-line, that of crude oil exploitation. So don’t hold your breath waiting to hear something positive about any of the so-far failed Alaskan Natural Gas pipeline projects. Now Great Bear’s Duncan is quoted; “Our objective is not to waste the molecules. Not one BTU, actually, will be thrown away”? Dam, I’m laughing so hard the air molecules are reacting and out of control, akin to crude oil about to flow out of ENI's flare stack. Sorry migrating whales – it will only hurt a little, just shy away from that dead “krill”! But getting back to the “Alaska Natural Gas” export limitations, or ban. It's a show-stopping reality and not a single politician has made even a whisper over it. I guess with these scoundrels, the last laugh is on us! So if you are interested in some humor, about what is going on with all the fruitcakes thinking we need to extend U.S.A. Route 1 from Prudhoe Bay to Norway, read on the Petroleum News. But the true bottom-line, it is not a joke! These projects were blessed with failure from inception. And the other sad fact of the matter, the individuals behind keeping these things alive and well and furnished with cash, they should know better. But why spill the beans, as it may mean it is time to find gainful employment, instead of a cushion like job that wastes away this state’s future, has “zero” responsibilities assigned and most likely a Christmas bonus is an automatic, for the camaraderie and more importantly, the demonstration of Silence! Shoot the messenger? How about paying for the truth to be sequestered!

Please Deliver this Petition

Dear Mr. President Barack Obama;

15C §719J “Export Limitations” was in-acted as law to protect this nation’s interest. Please do not allow any dereliction upon this “Law” or changes that would allow Alaskan North Slope natural gas to be exported. As the present “Law” dictates, you must see to it that any exports “will not diminish the total quantity or quality nor increase the total price of energy available to the United States.” By allowing exports, in time that loss can only amount to higher prices – due lose of a commodity. Alaskan natural gas from the “North Slope” should remain “Stranded” until such time it is piped through Canada, as that country is exempt from the “Export Limitations” realizing that gas will fuel America’s needs. We should not allow exports outside the “Law”. Please take this under consideration should you be asked to lift the “Export Limitation” by Alaska’s delegation, or through “Special Interests” or through any request by the Governor of Alaska.

Respectfully Submitted, B. Dawg

info@messages.whitehouse.gov

Alaska Sell-Out

Dear Fellow Americans;

I bring this concern to all true Americans’ attention, as help is needed and only you can provide that help by taking a stand with me upon this dire concern. The state of Alaska is desperate for cash, which has alarmed the sitting governor – Sean Parnell – to the point that he wants to give away the farm. The fallout of this pursuit fostered by desperation will have devastating consequences upon this nation – unless we resort to “We the People” power to intervene. When natural gas reserves were losing ground on the supply side of the well known “Supply & Demand” equation down in the lower-48 states, the Presidential leadership looked towards Alaska as a saving grace option, as Alaska has stored away a treasure chest of what is defined as “Stranded Gas”. Basically speaking, since oil started traveling down the Trans-Alaska-Pipeline back in the late 70’s, the natural gas that comes topside with crude oil extraction has been re-injected for future endeavors – like bailing out the states when energy woes cause havoc. Now during those 30-years of oil development and exploitation, the state of Alaska has enjoyed a decent share of the profits from oil feeding the states, income for supplying the valuable feedstock to many refineries up and down the West Coast. At one time, Alaska supplied 25% of America’s daily energy needs. Over 30-billion barrels have traveled south from Prudhoe Bay, which has allowed the state of Alaska to realize a dividend giveaway for its residents, plus money to do just about anything - like proposing “Bridges to No Where”. But at the same time this wealth was filling the coffers and fueling corruption in politics – a.k.a. Alaska’s “Corrupt Bastards Club” - the state spenders went foolish and spent a whole lot of loot on ridiculous type projects that did nothing in efforts to help develop a sustainable jobs infrastructure. So that is where the desperation stems from, as the “sky is falling” with respect to income as oil production is slowing down and the present leadership has not read the writing on the wall. And during these years wherein Alaska was the top oil producing state, it still relied on hefty Federal handouts that were way above and beyond any other state of the Union – that is what happens when a state has powerful Senators and Congressmen writing the appropriations legislation. So with so much “pork” heading from the U.S. Treasury to Alaska, to fuel foolish projects, with the debt crisis upon “All America”, Alaska has become desperate and realizes the only way to keep it going like the “good old days” is by selling out America’s future. So I call on all Americans concerned, as Alaska is more concerned about the bottom-line then the future of America. It is time to voice a concern to President Obama. And herein exists the problem that provokes this concern. As it stands, there are laws, rules and regulations that prohibit exporting Alaska’s North Slope natural gas to foreign markets until such time the President “publishes an express finding that such exports will not diminish the total quantity or quality nor increase the total price of energy available to the United States”. 15C §719J “Export Limitations” was in-acted as law to protect this nation’s interest. But now that the state of Alaska legislators fear the honeymoon is over with, to what was for a long time unlimited loot from oil production taxation, they have called on the governor to sell out the resource to foreign interests - like China maybe. This sell-out is being accomplished without regards to the law that prohibits such transactions abroad. And to make matters worse off, the agencies involved in this secret endeavor, they understand it all too well but are hoping to find some way to skirt the “Export Limitation”. This gas from Alaska’s North Slope should remain “Stranded” and used only for America – that is the “LAW”. Some day this gas will be needed, and to sell it abroad just so Alaska can continue to bask in wealth and still see a pathetic jobs infrastructure unfold, it isn’t worth the effort. America needs to wake up and call on Obama or the next sitting President to never allow Alaska’s North Slope Gas to find permission to leave us behind. Now is the time for all “True Americans” to voice a concern over Alaska’s attempt to sell out this nation’s future. Write the President or use the below enclosed letter to help stop the Alaska sell-out!

Dear Mr. President Barack Obama;

15C §719J “Export Limitations” was in-acted as law to protect this nation’s interest. Please do not allow any dereliction upon this “Law” or changes that would allow Alaskan North Slope natural gas to be exported. As the present “Law” dictates, you must see to it that any exports “will not diminish the total quantity or quality nor increase the total price of energy available to the United States.” By allowing exports, in time that loss can only amount to higher prices – due lose of a commodity. Alaskan natural gas from the “North Slope” should remain “Stranded” until such time it is piped through Canada, as that country is exempt from the “Export Limitations” with the realization that gas will fuel America’s needs. We should not allow exports outside the “Law”. Please take this under consideration should you be asked to lift the “Export Limitation” by Alaska’s state or Congressional delegation, or through “Special Interests” or through any request by the Governor of Alaska.

Respectfully Submitted, American Citizen John Doe

Alaska – The “Great Cesspool”

So North Dakota is about to surpass California as 3^rd in command with respect to oil development. Alaska may also fall behind once again this race. This state at one time in history not too long ago enjoyed the kingpin position, but the good old days are behind us. Texas stole away the “kingpin” status from the “Last Frontier” and since then it appears there in no retreat. In my book, that is OK, as what is on the horizon with future development if continued unchecked may turn Alaska into a giant “Cesspool” - it stinks! Gone are the days when 2-million barrels of oil rolled down the Trans-Alaska-Pipeline towards Valdez. And the trend will continue, the downward spiral with Alaska loosing out as 2^nd on the elite list, then down and down and down. Now the state regulators went stupid when oil throughput started declining drastically in early 2007 and put up an “Open for Business” sign accompanied alongside Her Governess Sarah Palin's hugshot - embracing schizophrenia - in efforts to entice novice like oil investors to come north and develop where no decent oil company had developed before. Believe it or not, this state was lucky when the oil fields were monopolized by “Big Oil” and the little guys knew best to stay away. But good things come to an end, even after 30-years of little to no competition. At least there was some environmental stewardship towards the “foot-print” we leave upon the fragile tundra and ecosystem during our ways and means to extract resources. Nowadays, there is a push on to turn this state into a “Cesspool”. Case in point is the history behind Pioneer Natural Resources, the 1^st “Independent” to brave the North Slope of Alaska, in efforts to waste away the shareholders future. So if this company cares not about its investment members, why should they care about what they leave behind in Alaska? The Oooguruk oil exploration and exploitation project located in the once pristine waters of Harrison Bay on the Colville River delta, it is not panning out anywhere close to what the executive board would like to happen, that is why a management change is occurring. Good thing for this Texas based oil company that the price of oil has remained so high, as when it tanks, so will this company's stock. And the sooner they leave, the better. Maybe with this management change taking place it means packing up already. Let's hope so. Unless we want to see this state turn into a real “Cesspool”. Just recently, Pioneer sanctioned the AOGCC regulators to allow drilling for oil in the “Torok” reservoir, because the oil development from two other formations already permitted was not panning out as expected, maybe flakes instead of nuggets. By this time in the project, Pioneer was supposed to be producing about 20,000 barrels per day of low grade crude oil. See, early on the company's down-hole geology gurus said to drill into the Kuparuk and Nuiqsut formations, as the Torok formation was messy. Now in efforts to perform oil development, it takes a “disposal well” approved by the EPA to get rid of oil field waste, which includes all kinds of things, from nasty chemicals to human crap. So Pioneer choose the “Torok” formation as its disposal site, getting approval from the state and Fed.'s as this formation was at a shallower depth then the Kupauk and Nuiqsut formations along with the fact that there was available a “clay and shale” buffer zone, so the permitted disposal well's effluent was to stay out of harms way, from any communication with neighboring formations. All was good! But with Pioneer sanctioning the regulators to drill for oil in the “Torok”, it is basically getting permission to drill into A “CESSPOOL”. Pioneer created the underground “cesspool” and now they want to tap into it. And this disposal area has become a human waste “cesspool”. Look, on a small man-made island with about 120-workers, with food available 24/7, there is a whole lot of crap to contend with. And with running water at a limit, the crap must be collected in a giant tank and pumped under high pressure down-hole to this well designated as an EPA certified waste disposal well. Yes indeed, it takes a permit from the state and EPA to send crap into the underground. So when the Kuparuk and Nuiqsut formations started to peter out, Pioneer went desperate and sought approval to develop the Torok formation, which is the “crap” field. They never should have been allowed to mess with this messy formation, now that crap has been injected down-hole for the last 4-years, along with other oil field wastes. One bad “Frac” shot in the “Torok” formation, if not already contaminated from natural fractures and the fact that the “crap” is injected at very high pressures above and beyond any documented formation pressures, it means “contamination” of “OUR” natural resources. And this is what the AOGCC should be looking at, instead of being pressured into letting the “Independents” operate under what amounts to be “blind” regulation. It appears that after Sarah sat on the commission's board under Frank Murkowski, regulation went re-defined! Look, I am not a geologist, this is simple dirt mechanics at work this situation. In fact, when Pioneer applied for drilling into the “Torok”, there came no mention of the disposal well in the same general vicinity, like this was an intentional smokescreen “out-of-sight, out-of-mind” manipulatory move. Not to mention that if “communication” takes place and the recoverable crude oil becomes contaminated, it places over 690-million barrels on the “non-acceptable” list, it would amount to a great loss to this state's resource royalty income – defined as lost production! See, if crap gets into the crude oil stream coming topside from the “Torok” formation and enters the Trans-Alaska-Pipeline, the state will have to shut down production, as crap isn't allowed to enter the stream. So the state regulators are once again asleep at the wheel. But do you honestly believe that the state regulators give a rat's ass about worker safety? They live and work about 800-miles from the oil fields and pipeline, where one finds flush toilets instead of having to “crap” in bag – as is the case in some remote oil drilling camps. So from the comfort of their luxurious office, they see no problem with “crap” contamination as the recoverable oil makes money for the state. If I were a worker along the pipeline, I would seek legal advice and advise on any and all contact with the existing crude oil stream, as it is all mixed together once it enters the 1^st pumping station in Prudhoe Bay. See, nobody would have to take responsibility if workers start getting E-coli “gut” sickness. Pipeline workers come in direct contact with crude oil each and everyday of their work routine. From laboratory workers called on to check the crude oil characteristics to maintenance workers who come in direct contact with the crude oil to fix things, like valves and pumps. So now that Pioneer has been granted permission to suck oil from the “Torok” which has already begun production without any increased testing for “crap” contamination, there now comes the possibility that “crap” may be coming down the 800-mile long pipeline, yes fecal matter, because we have regulators missing in action or regulators that don't understand the severity of their actions and inactions, or regulators that fell in love with Sarah's love affair with “Little Oil”, the “Independents”! Yes, these “Independents” are heading North to Alaska and are getting away with shitting on our front lawns and scenic walkways and letting it sit and set for someone else to pick up. Alaska, once the “Last Frontier”, now maybe the “Great Cesspool” state, Sarah Palin's Alaskan legacy!

Local Hire Issues

Now that the Alaska State Senate Labor & Commerce Commission has convened to study and investigate North Slope labor practices, outsiders verses insiders, I offer testimony. I worked for Pioneer Natural Resources soon after start-up of its Oooguruk oil development project until it was time to hang it up, as it was clear and convincing that this “Independent” was pretty irresponsible, upon the environment and many other areas wherein responsibility was mandatory – but nobody was watching. Maybe being new to the lucrative North Slope oil business and in competition with “Big Oil” made a difference, as I was used to seeing things done right, or at least an attempt to do things right at any expense - including the hiring practices in efforts to draft and retain the most qualified individuals, those with North Slope experience. When I worked for “Big Oil” I had this badge that weighed in at close to a 1/2-pound, with all these credentials for mandatory training, on just about every subject pertaining to doing business up north. At Pioneer's man-made island in the Colville River Delta, gateway to the Beaufort Sea, it was a whole lot different. It was basically like kindergarten, wherein new hires were welcome and made up a majority of the workforce, but without an experienced backbone, it meant a whole lot of trial and error “errors”! This was not a place to test things out. And what was heart-breaking was the fact that a majority of the workers were from outside, as Pioneer did not seek qualified workers from local job fairs. Did you ever see a “PNR Help Wanted” add? And there were factors that fostered this type of dereliction. First and foremost, as an Independent with not so deep pockets the hourly wage offered potential employees was no where near in comparison to what could be realized with a “Big Oil” company, so it usually meant unqualified labor, wherein many hired had no idea what it meant to perform up North – that “responsibility” thing. And what was the sad fact of the matter, there was no excuse for labor rates that disallowed for experienced craftsmen, as Pioneer sought and was awarded “Royalty Relief” by the state early on this venture. In fact the PNR CEO visited your chambers down in Juneau on several occasions when this Texas based oil developer went “Texas Hold'm” gambling for such relief, and talked up a storm about hiring in-state “qualified” help which would require decent wages and with a little help from the legislators with the “relief” would allow for hiring the highest caliper of help money could buy, or something to that effect. So relief was granted, but even though it helped the bottom-line and this CEO made a pretty hefty take-home pay, it didn't help in the worker ranks wage base. It is all based on money. The wage difference is about $15.00 an hour. That equates to an annual benefit of $40,000 a year! So the operation would hire unqualified help and soon after a little experience under the belt, even new hires would find work across the gravel road, at Conoco or British Petroleum. Talk about a pay raise. See, local hire usually meant experienced and qualified individuals as a whole, as a whole bunch of us have been at it for 30-years by now. If you can't pay the prevailing wage, it means “outside” help to fill the vacancies. So if you hear a bunch of hoopla from industry bosses during this session before your committee on “Local Hire”, especially from a company that receives relief, it is all a smokescreen. They asked for relief, you came through, then we were all fooled. Like is required for hazardous waste clean-up crews and many other “mission critical” jobs, Independents should have stricter hiring practices that are policed with respect to “qualifications” and that will cost more as it is the cost of doing business up North. That may not sit well with the shareholders, but so what. I know that is a “Big Brother” syndrome, more control, but if we lose it due irresponsible behavior from inexperienced hands, we loose any chance to develop further into the Beaufort. Bottom line, you get what you pay for. But there is a simple solution. It is called a UNION or in softer tones, “Collective Bargaining” wherein a contract provides a pay that keeps people from looking elsewhere and with that ownership, which equates to “Responsibility”!

Beaufort Sea

Dear U.S. Senator Lisa Murkowski(Alaska):

The following was most recently released through the news-media:

U.S. Senator Lisa Murkowski said a major oil spill in the Arctic would threaten to end production in the region, production that is already happening off the coasts of most far northern countries. Murkowski told an East Coast conference early Tuesday the United States should strive to be the "leader in offshore energy development" to pursue "twin goals" of environmental protection and domestic energy security. I think we all know there can be no mistakes along the way — we've got one chance to get it right, she told a Center for Strategic and International Studies audience. Murkowski said the absence of "coherent" implementation of national offshore development policy, coupled with the regulatory uncertainty and threat of litigation allowed by a blurry regulatory web, injures the investment climate needed to attract infrastructure to let agencies prepare for a busy region. She said U.S. production of Arctic oil, including an estimated 24 billion barrels beneath the Beaufort and Chukchi seas, and natural gas is crucial to the country's economic interests and for responsible development in the broader Arctic region. Murkowski's speech was part of a conference examining key issues impacted by last year's Deepwater Horizon spill in the Gulf of Mexico. The Arctic is believed to hold around 13 percent of the world's untapped oil, with the northern Alaska basin representing a significant portion.

Feedback:

With respect to your opinion and or views on this subject and for the record, maybe the “we've got one chance to get it right” has already been blown in Alaska! Not an all out blow-out, but there has already come the opportunity to oversee, inspect then gage what can be expected unless stricter control and oversight is called for in efforts to guarantee to the American public that offshore oil development will be orchestrated in such a responsible manner that indeed is focused for success with a “twin goals” approach in mind, namely environmental protection and domestic energy security - just like you have suggested in the above captive news release. So I urge you and your colleagues engaged in the topic of Arctic oil development to request and study the report titled, “Alaska's Deadliest Sin”, a “public domain” document available from the Alaska Oil & Gas Conservation Commission - which I authored while employed by Pioneer Natural Resources at its Oooguruk Production facility located offshore in the Colville River Delta, gateway to the Beaufort Sea. What I had witnessed and documented over 2-years on the job was gross mismanagement along with an irresponsible behavior mentality by the 1^st Independent to break into the lucrative crude oil energy business challenging the North Slope of Alaska. The report is critical upon PNR along with the state of Alaska and goes to show that the state regulators can not be trusted to make sure development, if allowed to go forward, moves along to the point that it does not impact the state's environmental rating towards the negative. It is evident from my perspective that the state of Alaska bureaucrats will turn an eye to get the Independents to go where other responsible oil companies have decided “NOT” to go in pursuit of the “Black Gold”, wherein the state allows for preferential economic breaks and it appears “oversight” breaks for these newcomers - the Independents - which will inevitably harm the environment if the status quo goes on unchecked - if such a mentality continues as it appears to be the case with PNR's Oooguruk project. And it is well known that ENI, the 2^nd Independent to brave Alaska's Northern coast for both on-shore and off-shore energy oil exploration and exploitation, the Nikaitchuq project has had its fair share of problems – blowing crude oil out a safety flare stack designed only for gas and a pipeline leak detection system that does not work as required and possible polar bear denning harassment. It is noted that ENI's Nikaitchuq project is in close proximity to PNR's Oooguruk development project, so it appears that we have before us an area of development by and through the Independents that could be used as the litmus test, to study how the newcomers score with respect to environmental stewardship. It appears that the Independents might be making advancements in the Arctic ahead of the major oil companies, because of preferential treatment – advancements both onshore the Beaufort Sea coast and offshore the Beaufort open waters. So far and early on the Independents' career here in Alaska, with respect to environmental awareness and stewardship, it doesn't look so promising. A relevant case in point with respect to PNR's Oooguruk Operation is worth entry this correspondence: The largest “illegal” dumping on record to date for Alaska's North Slope occurred through PNR in 2009, when 49,000 gallons of contaminated glycol was “sham” recycled down-hole without a permit, the latter permit required by the AOGCC. It was a PNR management decision, not an accident or equipment malfunction, to get rid of the contaminated fluids as there appeared no other option then to hire an expert hazardous waste contractor, which would have been a costly venture. The Independents have not deep pockets like the majors working the Alaska oil scene up north, so cutting corners will occur if left unchecked. So the PNR operations was required to perform an “illegal” operation. When I first brought this illegal dumping to the attention of authorities, it was denied. When more evidence surfaced, PNR was slapped a $10,000 fine, no where near a deterrent and a joke in comparison to what the major oil companies have been subject too for much smaller attacks upon the environment, with respect to fines to deter future irresponsible behavior. And when the regulators realized they had let down their guard and let down the state in efforts to make sure things like this cannot and will not happen, they amended PNR's permit, to allow for glycol injections, after the fact. Like an attempt to soften the blow of lack of oversight. All attempts to engage the EPA and or the Department of Justice to investigate this matter has gone without merit, not even a feedback correspondence explaining matters of jurisdiction or credible reasons to not investigate this matter, my concern. This appears to paint a bleak picture with respect to “oversight”, not only upon state oversight dereliction, but also a problem on the Federal side. Bottom-line, for PNR to perform this act without a permit, it is a crime, it is illegal according to Alaska statutes and PNR should have been held deterrent-accountable for the action upon the “sham” and held accountable on the fact that when given the last clear chance to alert the authorities about this activity, instead of honesty, it was an attempt to hide the truth at the same time an attempt to slam the whistle-blower. It seems like deja vu all over again, “Alyeska Pipeline Service Company Covert Operations”, wherein whistle-blowers were targeted. So there exists evidence in and around the Beaufort that should be studied to analyze what is already going wrong with offshore oil development on Alaska's northern coast with the introduction of a new breed, the Independents, wherein small marginal fields are being developed by what appears to be lack of oversight along with tax incentives, all at post haste speed, in efforts to fill the TAPS system. Once again, if we can't get it right here, it would never get done right, especially when further away offshore in a place that is very difficult to engage development activities all the time correctly along with proper oversight not afraid to perform as required to make sure we indeed do it right, all for America's energy security. Thanks....Concerned American/Experienced North Slope Oil Field Worker.

BP Consent Decree

This is my response to the U.S. Department of Justice with respect to the “Consent Decree” wherein BP is to pay a $25-million dollar fine for an oil spill on the North Slope of Alaska in 2006:

In reference to “United States v. BP Exploration(Alaska) Inc.”, please enter the following “comment” as allowed under section 102 of the Consent Decree, “Public Participation” and entered in accordance with 28 CFR 50.7:

Relief Requested: The fines and penalties assessed upon British Petroleum Exploration(Alaska) Inc., by and through the U.S. Department of Justice, appear excessive and should be decreased accordingly, based on similarly situated EPA violators, the area wherein the violation occurred, and the amount of discharge that warranted a criminal violation.

History: In April of 2010, a complaint was filed upon Pioneer Natural Resources(PNR), a Texas based oil exploration corporation, with respect to illegal discharging of “used”, not for resale and possibly contaminated propylene glycol. This occurred at PNR's Oooguruk exploration and production facility located in Harrison Bay, Colville River Delta, situated offshore in the Alaska North Slope Borough proper. It is noted that the BP Ombudsman's Program assisted the efforts to have this complaint taken seriously. The individual filing said complaint, at the time a direct PNR employee, had used the BP program in the past while performing contract work at a North Slope BP facility, so credibility and worthiness was already established. It is believed that it was the interest of the BP Ombudsman that promoted the PNR management to take the employee complaint seriously. PNR management did, by instigating an internal investigation upon the glycol discharge allegations. PNR also incorporated the expertise of an attorney well versed in dealing with environmental issues and crimes and familiar with the workings of the EPA. According to a report filed with the Alaska Oil & Gas Conservation Commission – the entity that maintains jurisdiction upon Area Injection Orders and is the local oversight for EPA rules and regulation, to what can be legally permitted and discharged underground – PNR denied all allegations and admitted “zero” discharges of glycol or any other EPA regulated wastes. This report was also forwarded to the Region 10 EPA director and to the Alaska Attorney general's Office, said again, denying all allegations of illegal discharges at the Oooguruk facility. Soon after that, the employee that filed the original complaint left said employment with PNR and provided more evidence to the contrary, be it the company's own “Daily Log Book” - a legally binding document - wherein there existed excerpts and entries that documented the illegal glycol discharges. Upon receiving this evidence wherein PNR could no longer deny the discharge allegations, the investigation team through its retained attorney amended the report to the AOGCC and admitted to the illegal discharge, without a permit, to 49,000 gallons of used glycol. Upon receiving this information, the AOGCC assessed a penalty and fine that was in no way shape or form a deterrent. The fine and penalty amounted too $10,000 dollars. First and foremost, PNR did not notify the EPA as required by law. Secondly, at the first clear chance to admit this occurrence did indeed happen, PNR denied all such allegations, making this known to the oversight agencies, as if allowing “closure” upon the allegations and complaint, making it appear that it was a complaint by a disgruntled employee. This inconsistent fine with respect to the size of the discharge was due the fact that the AOGCC could find through the evidence that the illegal discharges occurred as documented on only two occasions, assessing the maximum fine of $5000.00 per occurrence. There were many undocumented discharges throughout the summer of 2010 to get rid of the glycol when conditions warranted the availability of pipeline capacity to slipstream the “glycol” into the injection water line. This fine amounts to approximately 20-cents per gallon, for what is truly considered illegal activity. On the other hand, the BP pipeline rupture was an accident, not intentional. It may have been caused by lack of maintenance, but once again said, not intentional like the PNR discharges. At PNR, the operators were instructed to pump the glycol for no other apparent reason but to get rid of it, as it could not be sold, possibly due contamination. There was originally over 180,000 gallon of glycol at the site. Most of it was sold upon completion of the facility start-up. What could not be sold was “sham” recycled, without a permit to the underground strata not designed to handle this fluid. For BP's pipeline leak, the fines and penalties amounted to approximately $117-dollars per gallon, well over the AOGCC assessed PNR fines and penalties. The BP fine and penalty in comparison demonstrates a case of abuse and should be reduced to reflect what PNR was assessed. Any other action or inaction this request may be considered discrimination upon BP, for an accident in comparison to a non-accident resulting in an environmental crime of choice.

Respectfully Submitted, May 6^th, 2010

Coincidence NOT

So everybody of authority or those blinded by the right are in awe that a baby polar bear has been rescued from the North Slope oil patch and zoo keepers are in the process of finding this recently born youngster a new home, for now it means city life at the Anchorage Zoo. Pathetic this awe! Pathetic this excitement! Pathetic the authorities that see this as useful advertisement with a happy ending! As it is more of the same “shock & awe” in my book, basically inaction that is nothing short a blitzkrieg attack on peacefulness, a zealous attack on nature. Interference has got to be man’s greatest evil. I used to be an avid Alaskan oil field worker, but that career fell short its glory and thus, allowed me to advance intellectually wherein now I am a strong conservationist. I guess evolution does work! And I have all the proof in the world to support my “conservationist's” attitude, especially targeting the North Slope Armageddon. What I have witnessed recently in the “patch” is a whole different mindset that is set on tearing apart what required many years to foster, wherein there existed some semblance of care and respect towards the Mother Earth and the natural inhabitants, including polar bears, the focus of attention was clear - all throughout the Prudhoe Bay oil field domain and 800-miles down the Trans-Alaskan-Pipeline. And the EXXON Valdez was no accident, so don’t blame the oil workers, or captain Hazelwood either. “Things are different today, I hear every mother say”! Just ask the sow! This polar bear rescue making headline news should never have been allowed to occur. It was caused by disruption from the new players on the leasing block, namely the “Independents”, outside corporations – some of foreign background - that have found a place to explore and exploit the “black gold” without the slightest regard for the environment. Because nobody is watching! Because nobody is doing their jobs! It has become a hands off, turn thy head, blindfolded we go affair. Talk about the hen house being raided! The bureaucrats have put up an “Open For Rape” sign at this state’s front door. The Arctic is doomed. May as well “nuke” the Arctic Ocean to get rid of the ice pack, to make way for unadulterated abuse just so Alaskans can continue to enjoy welfare - a.k.a. PFD. If some of our representatives had it their way, the “nukes” would have already been called into action. Remember, it is a waste land - according to Ted Stevens - so what’s the problem with a little more messy waste? Now the polar bear cub was found separated from its mom, in close proximity to the Alpine oil production facility, which is located in the Colville River delta. Wow! This is God’s country. Man has no permission to descend upon this area with giant drilling rigs, there is no justification to ruin this place. Now the fact that a polar bear is missing its mom is cause for concern. It is just not an anomaly, an aberration. See, a few weeks ago, there was a similar incident. Something is causing nature to go upset, and it is because of mankind’s interference and trespass. Over at Oliktok Pt., the ENI operators were surprised to wake another sow denning with a cub on Spy Island. Two incidents in less than three weeks time, this is no coincidence and is proof that this new age oil development is disrupting tranquility. The fact that the cub was orphaned, it is something that should be taken seriously and investigated. Something out of the ordinary caused this event, and it is not global warming. And the fact that ENI may have been operating in an area without a polar bear infra-red survey, this goes to show that oil development is causing undue harm to the polar bear population. This area is well known for its good habitat for denning. The fact that ENI did not realize there was a denning white bear with cub on the island – a man-made Alcatraz that will soon be the site of a gigantic and noisy drilling rig come fall, it is inexcusable. The permit to operate requires the operator to make sure there is no denning within a mile of man-made activities, through surveys, and if a den is found – from heat radiated by mom keeping her babies warm through a brutal winter – it is supposed to be off limits to all activity. Had they performed the necessary survey and found the den early on, it would have presented a dilemma with their plan of attack, to have a drilling rig placed on the island this season. See, it would have meant a delay and that equates to a delay in oil sent down the Trans-Alaska-Pipeline which means a delay in income for the state. The entire health and well-being of the North Slope is now tied to income. When that priority enters the equation of greed, it dooms everything else. What is going on in the oil patch to fill the void is sinful. And the way other “Independents” in this same area are running their operations without any oversight, of course the polar bear population will suffer. What do I mean “no oversight”? Fact of the matter is this. The state wants oil, at any expense, to fill the void in the Trans-Alaska-Pipeline. So it means turning away from any kind of oversight that could dampen enthusiasm to develop oil where no oil has been developed before. And that means going into pristine areas, were once not too long ago polar bears reigned above the nuisance of man and drilling rigs. So in ending, it is time for a moratorium, time to refocus our attention on ANWR, time to expand protection to all coastal areas, as we can no longer trust the bureaucracy. If not, we will loose in the end, as when polar bears begin to show signs of frustration and forced to abandon their security, abandon their young, there is a deeper problem that is brewing down below and the doomsday clock has run out of time. Support a moratorium on near-shore and off-shore oil exploration on Alaska's northern coastline, as it is getting too late and nature can no longer defend for itself against these “Independents”!

Environmental Catastrophe Recap

A recap upon Alaska's North Slope largest “non-accidental” illegal discharge of hazardous waste.

There was a time in history, before the EXXON Valdez wreck, wherein oil field workers would come to odds with so-called environmentalists. It was “Oil Men verses the Green Guys”. I was an oil worker and at the same time a “green guy”. I remember many Totem debates with environmentalists down in Valdez, wherein I, along with my co-workers would win out the debates every time. See, what the environmentalists didn't realize or refused to accept was the fact that it takes an environmentalist's attitude in the field to make sure “Big Oil” maintained some semblance of environmental responsibility. Don't laugh! Look, when we were not at work making sure 2-million barrels of the “black gold” was making its way down the Trans-Alaska-Pipeline, for most of us it meant a week or two off the time-clock with unabated freedom surrounded by the greatest wilderness still “wild”. When the “Last Frontier” meant something. It meant spending a whole lot of time out fishing, hunting and hiking. We learned early on that we had to maintain this beauty for future generations, our children, as most of us where raising families during this time period. So we would be fools to let the natural beauty of the “Last Frontier” erode away just for the “black gold”. With that said, we became internal whistle-blowers, making sure that management couldn't pull a fast one to the detriment of the environment. It was the ultimate homegrown oversight. Look, we didn't need the state oversight to police the ways and means of the industry. We were on-sight all the time, official oversight only some of the time. And we were taught to make sure things were done right! Sure there came “accidents”, but what we are seeing today is a pathetic journey down the road to environmental ruins. I am talking the “Independents” that are given tax relief and royalty relief and with that a “license to kill”, leaving all environmental responsibility checked at the door. Case in point: The largest “non-accidental” illegal discharge took place about a year ago. It was at Pioneer Natural Resources' Oooguruk facility, located on Harrison Bay of the Colville River Delta, a gateway to the Beaufort Sea. This is pristine wilderness, the backyard of the Inupiat landholders, not in any shape or form desolation row or a wasteland. But when used glycol could not be sold, it was “shammed” away down-hole, injected out-of-sight without the proper permits. When first reported to the company management, not outside to regulators, PNR representatives denied all such allegations. And to try to discredit the individual worker that maintained a concern over the illegal discharges as defined by EPA guidelines, the attorney representing PNR went crying to the AOGCC, once again denying all allegations. PNR wanted to get it on record that nothing happened, as they supposedly performed their own internal investigation. Didn't we learn in kindergarten not to tell lies? But when evidence to the contrary surfaced, then the management realized they were caught red-handed without a plausible lullaby. So overnight it went from no illegal discharges to over 49,000-gallons of contaminated glycol now reported to the agencies in charge. The entire ship of fools it was! This is the largest “non-accidental” discharge on record for the “slope”. Because the oversight was lacking and could have prevented this had they been performing “oversight”, the regulators fined PNR a measly $10,000-dollars, a pittance and equal to about 20-minutes of crude oil production. As was the discharge a “sham”, so was the fine! At the same time, the Justice Department fined a fish processor $1.9-million in fines, for discharging a far less amount of glycol during a fishing operation in the Gulf of Alaska waters. That fine was based on the fact that the operation did not have the proper permits and the discharge was not an accident. And the fish processor didn't deny the discharge, but self-reported the ordeal, like is required by law. PNR did just the opposite, tried to hide it. The $5,000-dollar fine that PNR received for the illegal – without a permit – dumping, is is in no way shape or form a deterrent. It is a joke. But when we have a panic stricken legislature that wants to fill the void in the pipeline, with the likes of the Independents infiltrating where there was at one time some semblance of environmental responsibility, may as well shut-down the regulators, as it is business “not as usual” in Alaska's oil patch. Maybe the North Slope “wasteland” label will become fact over fiction, as just a few weeks ago and within eyesight the Oooguruk dumping grounds, ENI blasted crude oil out a flare stack at its Nitaitchuq production facility, only tens days after starting up the operation! The Beaufort is within a stones throw. Sorry, no fine! Had this been BP or ConocoPhillips, we would see a completely different outcome. This is a joke but not a joke, because ENI didn't even know who to call! They finally called the State Troopers! They don't even understand the proper reporting criteria, but still they have a permit to drill for oil? Doesn't the state perform a background check on the Independents? Look, I can't get by security on the “slope” without a personal background check, what gives. And this reporting wasn't a mistake, as it appears that it was all supposed to be under-the-table, just the way the Independents want it here in Alaska! They want their cake and eat it too. The fact that the EPA allowed PNR to get away with not even a slap on the wrist with the illegal disposal of 49,000-gallons of contaminated glycol, it is suspect. Hold that thought. It is beyond suspect and goes to show that things have changed on the “slope”, not for the good, but for the worse! There is no oversight, except for someone watching the money flow into the state coffers. May as well shut-down all the regulators, as we will save a whole lot of loot. So much for the environment. I am glad my kids enjoyed it while it was still “virgin” territory!

Update #1

Recently, the Justice Department levied a fine totaling $1.9-million in penalties and cleanup costs against UniSea Inc., for what could be gathered from local new articles, violations against federal and state environmental laws. It appears that what was missing this action that made it illegal was the fact that UniSea did not have the required permits for these particular discharges, including discharges of propylene glycol. There appears to be “grave” injustice this fine, as there are other “Clean Water Act” violators operating in Alaska that are getting away with far less fines and penalties for malfeasance well above and beyond what UniSea was indicted upon. In most cases, in no way shape or form a fine that spells it out that this kind of irresponsible behavior will be tolerated, as a deterrent. In a case of interest against Pioneer Natural Resources, the end result, it certainly does not send an important message of deterrence and accountability for environmental violations. Pioneer Natural Resources(PNR), a Texas based petroleum exploration corporation, was the 1^st Independent to operate on Alaska's North Slope, starting up the Oooguruk Island production facility back in 2008, located in Harrison Bay of the Colville River Delta, Beaufort Sea. As a direct employee during the early part 2010, I filed complaints internally with Pioneer's management with respect to illegal injection of used glycol, leftover from the warm-up start-up of the production facility's pipelines. Upon receiving my complaint titled “Alaska's Deadliest Sin”, PNR filed a counter-report with the State of Alaska AOGCC(Alaska Oil & Gas Conservation Committee), the regional EPA and the State of Alaska Attorney General, denying all and any illegal injection allegations, based on those complaints mentioned earlier. When I provided PNR and the AOGCC and the EPA further proof that the illegal injection did indeed take place, as documented in PNR's own “Operations Log Book” - a legal document - PNR amended their original report with the AOGCC, this time admitting to the injection of 49,000 gallons of used propylene glycol, without a permit. This is probably the largest illegal injection on record that ever occurred on Alaska's North Slope in 30-years of operation, with respect to the oil & gas industry. But in the end, PNR was fined only $10,000 dollars, or based on oil prices at the time the fine was levied, about 20-minutes worth of oil production time. The fine was meager and confusing, due the fact that the AOGCC could not determine how many days the illegal activity went on, evidence lacking, so PNR was fined the maximum daily fine of $5000, for two days only, or something to that effect. Had I not been persistent and had not before me the overruling evidence to prove that the illegal injections took place without the proper permits, as PNR's AIO(Area Injection Order) did not allow for glycol injection, PNR management would never had reported this and probably would have continued this illegal discharging until such time all of the questionable glycol was hidden away. And this “sham” recycling as it is called, it was done as a means to get rid of contaminated fluids(used glycol with elevated ph levels) that could not be sold for re-use. To properly dispose of this chemical fluid, it would have been a very costly venture, but it is the cost of doing business on the “slope”. It was not a mistake, I repeat, not a mistake or a defense that the “operators” thought it was OK from past experiences as the AOGCC report delivered by PNR finds so convenient an excuse as a lullaby. The operations' staff was instructed to do this by the PNR Operations Superintendent, through verbal orders, to get rid of the stuff he could not sell. The matter was of such concern to the AOGCC, it instigated a 3^rd party investigation upon PNR and the AOGCC's oversight capabilities, yet even today we see that PNR was levied nothing close to what could be righteously considered a deterrent. I have filed two complaints with the EPA over this matter, they have the reports from PNR, they have been in the loop, but nothing has come of my concern. Not even any feedback, as if they would rather not touch this one. I believe that the EPA is staying clear their responsibilities this issue for reasons that are not consistent its mission and goals, to protect the environment and prosecute violators. There is a lot of pressure from the Alaska legislature to make the Independents feel comfortable here in Alaska, to fill the so-called void in the pipeline, by developing “marginal” fields. Our own D.C. Delegation is behind the “Independents” success. I believe this is getting in the way of environmental stewardship. With that in mind, I have requested that the Justice Department in its authority, look into this matter as to what went on between PNR and the AOGCC and EPA, in efforts to make sure preferential treatment has not placed the oversight in a weak position. Once again, when one compares what PNR did illegally to that conviction upon UniSea, there is something drastically wrong this equation, with respect to the outcome. UniSea's fine, it is a deterrent. With Pioneer, more like a bonus!