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Exxon placed in evidence the extensive history, during
the 1960's through the present, of the State of Alaska’s
supervision of oil company abandonment and cleanup operations
of numerous North Slope exploratory well sites. Exxon
emphasizes and argues that such history and practice and the
AOGCC regulations (relating to abandonment of wells and to
cleanup of well sites) together establish affirmative DRR
obligations of the oil companies for all of the massive
equipment and facilities located in the entire Prudhoe Bay oil
field. One of Exxon’s experts states in his report as
follows:
The AOGCC’s record of strict enforcement of cleanup
requirements [for well locations] over the last
thirty-one years * * * evidences the State’s
commitment to having its lands returned in good
order and condition
* * *. [Emphasis added.]
We reject the equation, if that is what is intended by
Exxon’s expert, between well sites and the balance of the “lands”
constituting the Prudhoe Bay oil field.
Recognizing the dispute between Exxon and respondent over
alleged differences between well sites and the balance of the
Prudhoe Bay oil field, Exxon’s expert comments as follows:
It is not necessary to resolve the issue of what
constitutes a “location” to understand that the cleanup
requirements of paragraph 20, the AOGCC regulations,
and the consistent, virtually uniform pattern of
enforcement over many years, collectively illustrate
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