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leases, subject to the State's approval. Language in paragraphs
4, 7, 8, and 28 provides for suspension of operations without the
leases expiring.
Language in paragraph 33 of the DL-1 Leases provides that
Exxon (and the other oil companies), should it so choose, may
abandon or surrender its interests in the leases to the State,
provided it--
[places] all wells on the surrendered land * * * in
condition satisfactory to * * * [Alaska] for suspension
or abandonment; thereupon, * * * [Exxon] shall be
released from all other obligations accrued or to
accrue under this lease with respect to the surrendered
lands * * *. [Emphasis added.]
Alaska Law and Regulations Relating to
Exxon’s DRR Obligations in Prudhoe Bay
In 1959, the new State of Alaska Constitution provided for
“development, and conservation of all natural resources * * * for
the maximum benefit of its people.” Alaska Const. art. VIII,
sec. 2. Alaska’s land management policies generally allow
development of Alaska’s natural resources on condition that the
environment be restored to the maximum reasonable extent upon
completion of operations.
In 1967, the Alaska Oil and Gas Conservation Commission
(AOGCC) issued regulations relating to plugging and abandonment
of oil wells and to cleanup of oil well sites. See Alaska Admin.
Code tit. 11, secs. 2101-2108 (effective Sept. 1967), later at
Alaska Admin. Code tit. 11, secs. 22.100-22.110 (1973), and at
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