Willow would be the first large project constructed in the National Petroleum Reserve-Alaska, and ConocoPhillips’ 30-year lease was signed in 1999.
Under the terms of the agreement, the first oil must flow by September 2029. Writing to Gleason, Dunn said that “timely first oil requires a highly integrated series of construction milestones from 2023 through 2029, and there are no opportunities to further compress the construction schedule that would not create major execution risk.”
It’s possible that the federal government allows a lease extension, he said, but that’s not guaranteed. If Gleason overturns the existing approval altogether through what’s known as a “vacatur” order, it would likely cost ConocoPhillips at least two winter construction seasons, Dunn said, because of the time needed for federal regulators to redo the approval process.
“It could take years, depending on market conditions, to reassemble the right team to execute the project safely and efficiently,” Dunn said. “This is a real, practical consequence of a vacatur order, and it would weigh heavily against ConocoPhillips moving forward with a project that faces a risk of lease expiration.”
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